I don't believe your security agreement could reference the funds. It would have to be an additional task of after consummation, executing a security agreement. That's risk, cost and at the slightest indication that t"his is how this loan works," UDAAP.

Perhaps when you send the borrower away you indicate that they need to complain about this.

It looks like today's Q&A release by the DOD may have addressed this if I'm reading it correctly. https://www.gpo.gov/fdsys/pkg/FR-2016-08-26/html/2016-20486.htm

17. Does the limitation in Sec. 232.8(e) on a creditor using a check
or other method of access to a deposit, savings, or other financial
account maintained by the covered borrower prohibit the borrower from
granting a security interest to a creditor in the covered borrower's
checking, savings or other financial account?

Answer: No. The prohibition in Sec. 232.8(e) does not prohibit
covered borrowers from granting a security interest to a creditor in
the covered borrower's checking, savings, or other financial account,
provided that it is not otherwise prohibited by applicable law and the
creditor complies with the MLA regulation including the limitation on
the MAPR to 36 percent. As discussed in Question and Answer #16 of
these Interpretations, Sec. 232.8(e) prohibits a creditor from using
the borrower's account information to create a remotely created check
or remotely created payment order in order to collect payments on
consumer credit from a covered borrower or using a post-dated check
provided at or around the time credit is extended.
Section 232.8(e)(3) further clarifies that covered borrowers may
convey security interests in checking, savings, or other financial
accounts by describing a permissible security interest granted by
covered borrowers. Thus, for example, a covered borrower may grant a
security interest in funds deposited in a checking, savings, or other
financial account after the extension of credit in an account
established in connection with the consumer credit transaction.

18. Does the limitation in Sec. 232.8(e) on a creditor using a check
or other method of access to a deposit, savings, or other financial
account maintained by the covered borrower prohibit a creditor from
exercising a statutory right to take a security interest in funds
deposited within a covered borrower's account?

Answer: No. Under certain circumstances federal or state statutes
may grant creditors statutory liens on funds deposited within covered
borrowers' asset accounts. For example, under 12 U.S.C. 1757(11)
federal credit unions may ``enforce a lien upon the shares and
dividends of any member, to the extent of any loan made to him and any
dues or charges payable by him.'' As discussed in Question and Answer
#16 of these Interpretations, Sec. 232.8(e) serves to prohibit a
creditor from using the borrower's account information to create a
remotely created check or remotely created payment order in order to
collect payments on consumer credit from a covered borrower or using a
post-dated check provided at or around the time credit is extended.
Section 232.8(e)(3) describes a permissible activity under Sec.
232.8(e). However, the fact that Sec. 232.8(e)(3) specifies a
particular time when a creditor may take a security interest in funds
deposited in an account does not change the general effect of the
prohibition in Sec. 232.8(e). Therefore, Sec. 232.8(e) does not
impede a creditor from exercising a statutory right to take a security
interest in funds deposited in an account at any time, provided that
the security interest is not otherwise prohibited by applicable law and
the creditor complies with the MLA regulation, including the limitation
on the MAPR to 36 percent.

Yes, see the thread right above this thread.