If statements are returned due to a bad address and are held going forward does the 60-day period still start for the statements not mailed?

I believe Reg E says "when the information is made available". if the statements are not being mailed, i think you have a hard time making a case the information has been made available.

Well, if you have already determined that the customer no longer lives at the address to which statements are mailed, continuing to mail them present an identity theft risk. The statements are available, the customer just needs to come and pick them up or give the bank a new address.

The reg says from the date "transmitted.". There is a comment about out of the ordinary circumstances such as a hospitalization that would prevent the consumer from accessing or reviewing the statement, but I don't think moving without telling the FI counts as out of the ordinary.

Of course, the CFPB may take umbrage at holding the consumer to such a high expectation since moving is usually so out of the blue.