Currently today, we memo post all deposits to both Available & Ledger balance. Our bank pays items that come through a customer's account against Ledger balance.

We are thinking about changing not to post memo items to Ledger balance, only Available. B/c of this, we are considering to pay off of Available as well. Is this a common practice amongst other banks to pay off Available instead of Ledger? Is this a common practice not to post memo credits to the Ledger balance? I would greatly appreciate any & all feedback.

thank you

In my experience, intraday "memo" debits/credits affect only available balance. Ledger balance reflects items processed and settled. Reg CC allows the reduction of the available balance by contingent liability items (the memo debits); therefor, you may rely on available balance to honor OTC check cashing and other items presented.

We pay using Available Balance.

We have the following three balances on the main screen for an account:

1) Available
2) Collected
3) Current.

Available goes up and down throughout the day as memo debits and credits are introduced (ATM W/D's, deposits, etc).

Collected is current minus any transit items that were deposited within the past two days. Transit items effect Current Balance after two days.

Current is the balance at the close of the previous business date.

"Transit items effect Current Balance after two days."

You might want to review your float tables, as I doubt that "all" transit items create 2 day float. If you are paying interest on collected balances and not crediting the collected balance when you actually collect, you are going to violate Regulation CC.

Sec. 229.14 Payment of interest.

(a) In general. A depositary bank shall begin to accrue interest or dividends on funds deposited in an interest-bearing account not later than the business day on which the depositary bank receives credit for the funds

<--------just the Fraud Guy.

I'll look into that, Randy. We have a very good CO, so I'm sure we're doing the right thing. I'll post a clarification when I can.