I have a question related to whether a transfer is counted in the 6 transaction limit. I know the reg lists transfers to pay loans at the same institution are unlimited. My question is this: If a customer, at his discretion (not set up to be automatic every month), transfers money to pay on a loan using online banking (amounts differ each time), is that unlimited or counted towards the 6? I was under the impression that the automatic loan payments (the bank is authorized by the customer in writing) were unlimited, but if the customer initiated the transfer, it was included in the 6.