Ok so the take-away I get is that the docs could be updated since I'm sure many others like myself have assumed that the min or max accumulate functions will work for anything comparable. And yes, it would certainly be easy to write your own minDate accumulate function, or implement the min functionality just inside the accumulate (rather than using a accumulate function that does it for you). It would be more of a nice to have to have a pre-built accumulate function that works on comparable objects - making rules cleaner and easier especially for new rules writers - but certainly accomplishing the same task without them is no problem.
Thanks again for the tips and discussion.