We currently have some borrowers that get commercial loans in their personal names. Some of our borrowers never step foot in the bank. Right now their process is to have the CIP in the closing packet. I don't feel like this is adequate notice to the borrowers. I would like to know what other banks are doing to ensure their customers receive the CIP notice if they never step foot in the bank and there is no online application.

Here's the citation from the USA PATRIOT Act.

(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 Web site, include the notice on its account applications, or use any other form of written or oral notice.

So if the account is not considered "open" prior to closing, then this could satisfy the requirements. Additionally, you a permitted to make the disclosure orally, so you could opt to train your commercial lenders to read the disclosure to an applicant over the phone when they are collecting the personal information.