Yes, I think they are!
Their standard statement is based on a number of transactions, which equal “one page” on their layout. Their systems automatically generate a statement once you have “one page” worth of new transactions made since the last one was generated! At one time, they had no paperless option (I think pre-2016) and it worked the same way but automatically posted one - even more annoying! I saw somebody on MSE describe it as the “Co-op paper statement monster” which spewed out endless statements.