For Reg D transaction monitoring, may we opt to monitor transactions month-to-month if the account statement cycles mid-month to mid-month?

We have some accounts which cycle the end of the month and some which cycle the 15th of the month, but our reports monitor transactions starting from the 1st of the month. To make things easy, I'd liek to just go by the report's data, which means I'm monitoring transactions that will not all show up on one statement for those mid-month cycling accounts.

I can't find that I cannot do this. Here's the only excerpt I can find in the Reg:

"the depositor is permitted or authorized to make no more than six transfers and withdrawals, or a combination of such transfers and withdrawals, per calendar month or statement cycle (or similar period) of at least four weeks,"

That language is exactly what you want. You can monitor based on calendar month or statement cycle if the statement cycle is at least four weeks.