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.

Also, I'm assuming that if the customer calls the bank and has a teller transfer money from his savings to his loan, that would be included in the 6 because a check was not mailed to the customer as a result. Or is it unlimited because it is a transfer to pay a loan at the same institution?

"Such an account is not a transaction account by virtue of an arrangement that permits transfers for the purpose of repaying loans and associated expenses at the same depository institution (as originator or servicer)"

I see no qualifications on how the transfers are accomplished.