How CPA firm advisory partners can refer clients for data licensing, gate by gate

Why the advisory partner is the firm's natural referrer

The advisory partner holds the asset that matters most in a referral: a trusted relationship with an owner who already discusses strategy, succession and systems with you. Tax and assurance teams see the numbers; the advisory partner sees the decisions. That makes you the person in the firm best placed to raise a data license at the right moment, and the person most responsible for raising it properly.

Data licensing fits the advisory agenda because it turns records a client already keeps into a one-time payment for an exclusive AI-training license over an agreed term. The client keeps ownership, approves the scope and the price, and is bound by nothing until the owner signs. SourceX runs qualification, inventory, pricing, buyer review, contracting and delivery; your firm's part ends with a permissioned introduction.

The general page on referral opportunities for accountants covers bookkeeping and tax practices, and CAS leaders have their own referral program for client accounting services firms. This page is for advisory partners at regional firms, where independence, firm approval and partner-level relationships shape every referral.

Which advisory clients are worth a first look

Start with clients the firm knows well, and use only what the firm holds legitimately from its engagements. You are screening for a conversation, not assembling a file.

B2B software, IT services, engineering, professional services, distribution and the office operations of manufacturers tend to screen well. Medical practices whose files are mainly protected health information, and agencies holding their own clients' material, usually do not.

The three-gate approval path

Call it attest, approval and assent in your firm's policy. Clear all three, in that order, before the owner hears a word about it.

Gate 1: attest screen

• Check the independence system: does the firm perform an audit, review, compilation or examination of prospective financial information for this client or a related entity?
• Check whether the client, a parent or an affiliate is an SEC registrant whose financial statements the firm audits.
• If either answer is yes, stop and take it to the ethics partner before going further.

Gate 2: firm approval

• Confirm the firm's policy on accepting third-party compensation, and who in the firm would receive it.
• Have the ethics or risk management partner sign off on the referral and on the disclosure wording.
• Note the referral in the client file so the tax and CAS teams are not surprised.

Gate 3: client assent

• Disclose the referral relationship to the owner in writing, including that the firm may receive a share of SourceX's fee.
• Get the owner's permission before sharing the company's name or any fit information.
• Make clear that the owner, not the firm, decides whether to proceed at each stage.

What the professional rules say

The AICPA Code of Professional Conduct contains the commissions and referral fees rule at ET 1.520. It says a member in public practice may not accept a commission for recommending a product or service to a client when the member or firm also performs an audit, review, certain compilations or an examination of prospective financial information for that client, and that permitted commissions and referral fees must be disclosed to the client. Read the current text on the AICPA's own site before relying on any copy.

The contingent fee rule at ET 1.510 is the second one to check. A contingent fee is one whose amount depends on attaining a specific result, and members may not perform services for a contingent fee for a client where the firm performs audit, review, certain compilation or prospective-financial-information examination work. Ask your ethics partner whether any advisory work on the license itself could be viewed that way.

State law can add another layer. Florida, for example, regulates CPA commissions and referral fees by statute; the linked page shows an older version, so check the current statute and your own state board's rule. Firms that audit SEC registrants also answer to the SEC's own auditor independence rules on contingent fees, which SEC staff correspondence with the AICPA ethics committee treats as a regime separate from the AICPA Code.

This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

If the firm might also help the client prepare for a license, read whether helping a client license data affects CPA independence before scoping that work.

When to raise it in the firm's year

Stay away from busy season. A data license is never urgent enough to compete with filing deadlines, and an owner who first hears about it in a rushed call will remember the rush.

How the introduction works

1. Clear the three gates and record each approval in the client file.
2. Tell the owner about the option and the firm's referral relationship, and ask whether they want to look into it.
3. If they do, send the owner the referral link or submit the company through the referral form with high-level fit details only.
4. SourceX's team runs its own qualification with the owner or another authorized sponsor, covering headcount, operating history, the systems involved and the rights position.
5. The company documents its systems in a data inventory, agrees one all-in price and the terms with SourceX, and decides whether to sign.
6. AI labs and data buyers review the opportunity; once a company is deal-ready, buyers typically respond within about two weeks.
7. After signature the data is prepared under redaction rules agreed beforehand, delivered, and the company is paid; any reward to the firm comes only after SourceX receives its fee.

At no stage does the firm touch, transmit or characterize client records. Your confidentiality obligations cover everything you know from the engagement, so pass on only what the owner has cleared.

What to say to the owner

How rewards work for a CPA firm

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company. The reward is paid only after the buyer pays and SourceX receives its fee; an introduction, meeting or signed agreement alone does not trigger payment, and no reward is guaranteed.

Because the reward is a share of SourceX's fee, it never reduces the client's proceeds. Whether your firm may accept it for a particular client, how it is disclosed and who in the firm receives it are questions for firm policy and your state board. Decide before the first referral whether it is firm revenue, and register accordingly.

When to leave it alone

• The client is an attest client and the firm cannot accept compensation; decide with the ethics partner whether to mention the option at all.
• Peak headcount never reached 50 full-time employees, once contractors are set aside.
• Most of the client's records belong to its customers, patients or principals rather than to the client.
• The owner has already licensed the same records for AI training, or a court, trustee or assignee now controls the assets and has not been involved.
• Old archives were purged, or no one at the client can run an export.

The company fit checker gives a preliminary, non-binding screen with no contact details required, and who qualifies sets out the full baseline.

Next step

Take the three-gate path to your ethics partner this quarter and agree the disclosure wording once. Then register as a partner, clear one client through all three gates and make the introduction. Owners who prefer to look first can apply at sourcex.si/apply through your referral link.