Interesting little note in the staff interpretations to 1005.11(b)(1).
"Notice at particular phone number or address. A financial institution may require the consumer to give notice only at the telephone number or address disclosed by the institution, provided the institution maintains reasonable procedures to refer the consumer to the specified telephone number or address if the consumer attempts to give notice to the institution in a different manner."
Look at the Credit Unions EFT Disclosure. If in the error resolution section they direct the consumer to contact VISA directly using VISA's phone number and address and staff is properly trained to refer the customers to the VISA number or address, then they are in compliance.
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