Reg D and Internet Bill Payment

We're promoting internet bill payment services and savings accounts together. My concern is that if customers begin paying third parties out of their savings, wouldn't they violate Reg D after 3 third party payments? The Reg states "made by check, draft, debit card, or similar order and payable to third parties", but doesn't specifically cover these...

Bill payment transactions from a savings account/MMDA are subject to the transaction limits in Regulation D. They will fall under the 3 or 6 per month limit depending on how the transactions are made (ACH/check) and whether the bank uses a third party agent. Click HERE for an article that explains in more detail.

Thank you, thank you, thank you! This is wonderful. From our standpoint, it looks like if it's not ACH, it falls within the three transaction limit...