I had considered changing our quarterly statement savings accounts to a semi-annual statement for cost savings also. In researching this I looked at Reg E 205.9(b)that covers periodic statements. It says:
(b) Periodic statements. For an account to or from which electronic fund transfers can be made, a financial institution shall send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred.
I believe the operative phrase is CAN BE MADE. If you permit that class of savings accounts to have electronic funds transfers, whether they have them or not, then I read the Reg to say that you must have at least quarterly statements. If you get a different read on this I would appreciate your view.
We decided to stay with the quarterly statments rather than to set up another class of savings accounts that we would not permit electronic funds transfers.