Is your institution also allowing early access to ACH direct deposits like SSA, VA, payroll, etc.? I know a number of institutions have started doing that (Capital One is heavily advertising it). It's a management decision, and if you're getting those Venmo, CashApp and FB credits via ACH, you are accepting more risk for them (because there MAY be a greater risk of not having them funded).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8