Popmoney Considered Automatic Transfer? (Reg D)

It could fall under one of two categories (someone may know more definitively than me which one), both of which would be included in the count for excessive withdrawals. It is either a preauthorized transfer under this Reg D language: "A preauthorized transfer includes any arrangement by the depository institution to pay a third party from the account of a depositor upon written or oral instruction (including an order received through an automated clearing house (ACH)) or any arrangement by a depository institution to pay a third party from the account of the depositor at a predetermined time or on a fixed schedule" or it is a transfer made "by check, draft, debit card, or similar order made by the depositor and payable to third parties". In either case, it counts toward the limit of 6.