I recently read a Q&A from Bankers Online Learning Connect that says," Q. If your customer has his or her debit card stolen on a Health Savings Account does Regulation E apply?"
"A No, Health Savings Accounts are trust accounts and are not subject to Regulation E.
However, you should be careful not to put Reg E disclosures on HSA statements or to give them at account opening, because that might give customers the opposite impression
Since HSAs are exempt from Reg E wouldn't they also be exempt from the Reg E statement requirements?