Originally Posted by RJPA

Can confirm; as of January, 2019, all I had to do was call and they processed it. I've read several posts on here prior that the free days couldn't be transferred, so hopefully our posts will go toward correcting that misunderstanding.

A few things to note:
1. National manually processes the request, so it takes 3-5 business days. So plan ahead.
2. National converts the free days into codes and emails them to you and the recipient.
3. While the policy says up to 3 days per year, I was able to transfer 5 days on two separate occasions in January, 2019, to my wife. I even brought up the limit with the CSR on the second transfer request, and she said they are sometimes lax about the limit. Indeed, no fuss. I do think that because it's a manual processing (takes your request, reduces the # of free days in your account, generates a code for each free day, then sends email), they may not actually have a way to check the history for prior transfers. But that's just speculation on my part.

Happy driving~