I am anticipating pushback, though, since it is not required and wasn’t sure of the potential ramifications in providing a disclosure that is not required, promising to do something that is also not required.
The problem you have is that this is no longer a compliance issue. As you said, it wasn't required, so it isn't a regulatory compliance issue. Since you disclosed it, however, this becomes a potential contract issue and really a question for an attorney. One thing you could do is to give them two options: 1) follow through on what you disclose or 2) take it to their attorney for a legal opinion.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com