That should be possible. See the note in Section B of Appendix Q:
i. Effective income for consumers planning to retire during the first three-year period must include the amount of:
a. Documented retirement benefits;
b. Social Security payments; or
c. Other payments expected to be received in retirement.
Once they reach age 70 1/2, the IRA distribution is mandatory. However the bank should think long and hard about making such an assumption prior to the mandatory distribution date and whether or not it is in the best interest of the applicant.