Here's where renniks gets his or her material:
(5)(i) Customer notice. The CIP must include procedures for providing bank customers with adequate notice that the bank is requesting information to verify their identities.
(ii) Adequate notice. Notice is adequate if the bank generally describes the identification requirements of this section and provides the notice in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account. For example, depending upon the manner in which the account is opened, a bank may post a notice in the lobby or on its website, include thenotice on its account applications, or use any other form of written or oral notice.
Your procedures make this harder than it has to be. I encourage you to get rid of the requirement that the customer acknowledge receipt. It cannot help you, but if reviewers find files where there is no acknowledgement, it can definitely hurt you. Review your board approved CIP to see what you required there. Amend it if necessary.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.