Answer:
CAN-SPAM rules define a commercial electronic mail message an email (which is NOT what is on a closed loop like messages in an internet banking system), with a primary purpose of promoting a product or service and it is not a transactional or relationship message. Your survey sounds as though it would not fall into these conditions.
I would still omit names of customers who asked not to be contacted, and if it works procedurally, I would try to ask these survey questions when the customer actually closes the account.