Trust Created Within IRA Beneficiary Designation

Good morning, all. I thought I’d seen just about everything, but yesterday a new one came across my desk. I was asked to review a supplemental IRA beneficiary designation form where the disposition of the IRA looks like this:

Primary Benes = John and David, equally
Contingency = If either John or David isn’t 35 years old, then to a trust f/b/o respective bene

That part is pretty standard, but here’s what was different… the terms and conditions of the governing trust are created within this IRA beneficiary designation. There is no trust created under the account holder’s will or a revocable living trust referenced; the only trust is what is created within this document.

Has anyone ever seen this before and, if so, thoughts?

Thanks!

Jae