Does the reg address this? It appears the banks
are counting them in the 3 allowed per month but I thought I remembered that the Fed was lumping them in with telephone transfers that allow 6 per month. Any thoughts on this?

I'm counting them in the six.

We are counting them the same as telephone transfers.

Think of it this way: If it is convenient to do, it counts. Going to an ATM or the bank isn't, therefore they don't count.