If you tie a debit card to a HSA, wouldn't debit card transactions be limited to 3? You would also need a Reg E disclosure, correct?

Many, if not most, POS processors won't even handle POS debits to a savings account, but many providers are now touting HSAs that include a convenient debit card access. That leads me to believe these are actually classed as NOW accounts, which makes sense since holders of HSA accounts would qualify.

Yes, there would have to be a Regulation E disclosure.