How do you interprit Section 7216?

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According to irs.gov section 7216 the IRS requires that:

"tax preparers must obtain the signed consent of the taxpayer on paper or electronically before they can disclose taxpayer return information to anyone or use it for any purpose other than in the context of preparing and filing the return.
Separate consents are required for disclosure(s) and use(s)."

You want to outsource your Email newsletter. Technically the only way to send an Email newsletter from in-house is to buy an exchange server. The expense of buying an exchange server, bulkmail software, and hiring a skilled employee to maintain and secure it is currently prohibitive for most small accounting firms so currently this is invariable done by emailing from a remote server.

Would you interpret this, setting up a third party bulk mailer to send to your clients' email address without their express written consent, as a violation of Section 7216?
 

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