Would giving free coins to my early protocol users be considered as a security according to US SEC?

Hi, I am aware of the Howey test on how an asset can be a security. But, I am asking here to confirm my logic.

If we issue our coin free of cost to our early users, is it still a security? We are essentially a fixed income DeFi project. So, plan to give tokens to any user who invests in our investment products.

The utility of the token can be as follows:

1. Governance purposes
2. Dividend eligibility

So, would making the coin dividend eligible make it a security, given that it was given for free in the first place?

What are some ways to avoid getting in regulatory issues during the earlier stages in product? We don't have any issue being complaint but don't want to worry about it when we are young.