I know that electronic transfers count as a Reg D limited transaction, and I know that an in-house loan payment counts as an unlimited Reg D transaction, but does an electronic loan payment to an in-house loan done from a home computer count as a limited or an unlimited transaction?

I hate to say, it depends; but it may depend on the transaction code given at the time. Our internet banking transactions get a different code from loan payments, so it would count as a limited transaction. I would then review the report to see if it has a description of 'loan payment' or is somehow identified as such. If it is a loan payment, I allow it as unlimited due to the purpose.

Ours are coded specifically as a loan payment, so I will count it as unlimited. Thank you!

There's nothing in the regulation that requires the "uncounted" loan payment transfers be automated. You could ignore loan payment transfers made via internet banking if your system permitted you to do so.

we've been having a discussion about number of allowed transactions on savings/money market accouts. The question is whether or not an auto transfer for ODP from a savings/mm to a dda account is a covered transaction under Reg D? I think they are considered pre-authorized and count in the 6 allowed. Is this correct?

You are correct; it is pre-authorized and is a covered transaction subject to the limit.

Ok thanks so much.

Where is the reference in the Regulation that makes loan payments not subject to the "Convenient Transfer" classification? I'm pretty sure I have seen it before, but having trouble at the moment.

A nuance to this situation, what if a Bank charges a fee related to a loan program and the Savings Account is used to pay the fee? Do you believe this would be subject to the 6 transfers limitation if done through a "convenient" means?

You need to carefully read the full definition of "Savings Account" 204.2(d)(1) and 204.2(d)2)

https://www.bankersonline.com/regulations/12-204-002#savings