Scenario:
We are considering creating a new deposit account which, along with other features, would offer early direct deposit (i.e., get access to their direct deposits 1-2 days early). We would have an account level service charge for the account, but no fee specifically tied to the early direct deposit.

Questions:
Would this be considered an advance since we are making the deposit available before the "effective" date of the deposit? If so, would this be considered a "covered loan" under the Payday Lending Rule?