Ahhh, you're entirely right, I misremembered. Fees aren't required at all under Reg D (not Reg DD, damn alphabet soup). The FI does have a responsibility to monitor excess transactions and prevent non-occasional violations by either converting the account, or removing transactional abilities. So yeah, a token fee wouldn't be a viable strategy.

Getting back to the topic at hand though, I don't think this would be much of a problem for fancy automatic transfers. Deposits to savings accounts aren't covered transactions, so something like "If I spend less than x budget this week, send the rest to savings" would work.

If the FI designed a product that would see more frequent withdrawals, they could just designate it a transactional account and skip the whole issue entirely. Fits in the spirit and the letter of the law.