Hello,
If the notice is dated on the 180th day, is this sufficient? There does not appear to be a definition of “provide” in 1024.39(b). We generate the notice on the 180th day and date it as such, but does the postmark also then need to be that of the 180th day? Thank you.

I would not sweat it unless you think such notices sit in your mail room for more than 24 hours.

The 180 days is from the date of the prior written notice, so assuming you're using the same procedures, then you are probably fine. We send out at 175 to be safe, but examiners would have to be in a pretty bad mood to be looking that closely.

Only tangentially related, but my bank was once cited in an examination because the LEs were postmarked the day after they were printed, not the day of printing. The examiners theory was that the day delay in mailing might have put the date received by the borrower outside the regulatory window.

There is no theory involved there. If you printed the LE on the third business day after application and did not actually mail them until the fourth business day, you have a violation.

LE was printed day after application and delivered to mailing vendor that day. Mailing vendor mailed them next day, which was within the 3 day window.

Still a violation. Date issued is either the date the LE is handed to the applicant or the date it is placed in the mail. There is no wiggle room here for using a "mailing vendor".

1026.37(a)(4) Date issued. The date the disclosures are mailed or delivered to the consumer by the creditor, labeled “Date Issued.”