If we get an ACH and memo post it but hold the funds later in the same day, did we meet the requirement of Reg E to make them available "as of the date the funds for the transfer are received"? Or do they have to hard post to the account to meet this requirement?

When the memo post occurs can your customer access the funds at the teller, ATM, debit card purchase, will it cover items clearing the account that day?

If the answer is yes, you have met the requirement. If the answer is no, then you haven't.