I'll admit to not having read Visa's rule in detail, but I seem to recall that it's more protective of the customer. So, by way of a reply, I'll suggest that, if Visa rules require a provisional credit any sooner than 20 days, Visa rules will apply.
That said, your compliance with Visa rules remains a contractual one, between you and Visa. Compliance with Reg. E rules are regulatory. And regulators can enforce the latter.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8