I'll avoid the terms "available" and "unavailable" because with ODP they can be confusing.
If you provide a balance at an ATM, on a voice response unit, on your online banking system, or via any other automated system that can provide a balance directly to your consumer depositor,
1. That balance cannot include any funds from any source other than the account in question (it can't be "enhanced" with an amount that the bank would allow the account be be paid into overdraft, by an amount that could be transferred from a line of credit to cover an overdraft, or by an amount that could be transferred from another account of the consumer to cover an overdraft -- collectively referred to as "overdraft funds"). The balance can reflect holds placed under Reg CC for delayed availability of deposits by check, funds that have been memo posted to or from the account for ACH activity or pending deposits or checks taken at the teller line, etc.
2. In addition to that balance, you can provide a separate balance that includes "overdraft funds" if you prominently label it to indicate it includes overdraft funds.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8