The BSA/AML Manual addresses both issues in detail and its discussion of private banking pursuant to section 312 focuses on really high end clients, not just customers who are served by someone called a "private banker" who sucks up to them at the branch. The Manual indicates they require special attention when they are products and services offered by your bank. If you do not offer either, then the most your policy could say is that you do not offer them.
Sometimes auditors and examiners are like boys on their first dates: They can't think of anything to say, so they say something ridiculous. Your question should have been raised before you received your written report, but I suggest you respond in writing and ask for specific direction as to what is necessary and why it is necessary. It is important to indicate that you flatly disagree. Regulators often use reports of independent examinations as the springboard for their examination. You don't want them to get all excited about something that is simply irrelevant.
My favorite similar example was in connection with a criticism in a regulatory examination that the bank's policy did not address international shipments of currency. This was a community bank located in eastern Kentucky and, in its 108 year history, had never had an international shipment of currency. It takes an astute observer to come up with criticisms like that.