Answer:
No. The information required to obtain a Verified by VISA account could be obtained through fraudulent means such as phishing, publically available information on social media or people search websites, etc. This is not sufficient evidence to demonstrate that your customer authorized the purchase any more than relying on the use of a PIN at an ATM.
You inability to use the chargeback process to investigate the claim does not negate your obligations under Reg E.
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