Since Reg E was written prior to internet commerce being a thing, the commentary is missing internet transactions, but based on CNP mail and phone being covered, it's not a small leap to include internet. Yes, all debit card purchases can be extended to 90 days.
11(c)(3) Extension of Time Periods
1. POS debit card transactions. The extended deadlines for investigating errors resulting from POS debit card transactions apply to all debit card transactions, including those for cash only, at merchants' POS terminals, and also including mail and telephone orders. The deadlines do not apply to transactions at an ATM, however, even though the ATM may be in a merchant location.
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