We have a customer who made online payment from his bank account to a credit card account from his bank. Is this considered a loan, and therefore considered "not covered" for purposes of Reg. D?

I would say a loan includes a credit card payment. But is the deposit and the credit card debt at the same bank? That is what qualifies for the exception in transactions counts under 204.2(d)(2).

Yes, the deposit and the credit card are at the same bank. He was using the Bank's billpayer system to make the ACH payment from his savings to the credit card account. I was 95% sure that this qualified as a loan for purposes of the Reg., but wanted to get some other opinions before making my determination. Thanks!