AICPA confidential client information rule: what a CPA can share in an introduction

Short answer: what can a CPA share when introducing a client?

With the client's specific consent, a CPA can share the company's name, the contact details of the owner or executive who will sponsor the conversation, and a few fit facts the owner has confirmed in their own words. Without that consent, share nothing, including the fact that the company is your client. Financial statements, tax details, payroll data and anything else from the engagement file never travel with an introduction, consent or not, because SourceX does not need them and the company supplies its own information.

The cleanest route avoids disclosure altogether. Send the owner your referral link, and the company applies itself at sourcex.si/apply with your code attached. The client describes the client, and your credit is preserved.

What does the confidential client information rule say?

The rule sits at ET 1.700.001 of the AICPA Code of Professional Conduct. The AICPA's online Code is the authoritative version; a full-text copy of the AICPA Code hosted by the Minnesota Society of CPAs shows it alongside the fee rules. In substance, a member in public practice may not disclose confidential client information without the client's specific consent.

Three features matter for introductions:

• Specific consent. A general clause buried in an engagement letter is a weak basis for introducing a client to a named third party for a business purpose. Ask for consent to this introduction, to this company, for this reason.
• Narrow exceptions. The rule's exceptions deal with matters such as professional standards, subpoenas and summonses, applicable law, peer review and ethics investigations. None of them was written for business development.
• State law on top. Your state's accountancy law and board rules can impose their own confidentiality duties, and your firm's policy may be stricter than both.

Read the interpretations under the rule in the current Code as well. Until your own ethics resources tell you otherwise, treat a client's identity as confidential.

What does ET 1.520 add when an introduction can pay you?

Confidentiality is only half the picture once a referral reward is possible. Under the Commissions and Referral Fees Rule (ET 1.520.001), as set out in the AICPA Code copy published by the Minnesota Board of Accountancy, a member in public practice may not accept a commission for recommending a product or service to a client when the member or the firm also performs an audit, a review, certain compilations or an examination of prospective financial information for that client. Commissions and referral fees that are permitted must be disclosed to the client.

States can go further. The New Jersey Society of CPAs' resource on commissions and contingent fees shows one state's rules departing from the AICPA Code and being stricter in places. Check your own board's rule before you register, and check every state where you hold a license.

The introduction minimum: what to share and what to hold back

Use this table as the line between a clean introduction and a confidentiality problem.

How does the rule apply in common situations?

Getting consent that will hold up

1. Raise the idea in a meeting the client expects, such as year-end planning or a quarterly advisory review, and frame it as an introduction, not a prediction of any result.
2. Say exactly what you would pass on: the company name, the sponsor's contact details and the fit facts the owner just gave you. Nothing from the file.
3. Disclose in writing that your firm may receive a referral reward if the company licenses data and SourceX collects its fee.
4. Ask for a short written consent naming SourceX and the purpose; a client consent form for introductions gives you a starting format.
5. File the consent in the client's permanent file, then make the introduction or send the link.

Questions to ask your state board or ethics counsel

• Does our state treat a client's identity as confidential information in this context?
• Is an emailed reply enough consent, or do we need a signature?
• Do our state's rules on commissions and referral fees track ET 1.520, and how do they treat compilation-only clients?
• Must the reward be disclosed before the introduction, when it is paid, or both?
• If a partner holds licenses in several states, which state's rule governs?

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

How rewards and the program fit together

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, up to $100,000 per referred company, payable only after the buyer pays and SourceX receives its fee; no reward is guaranteed.

You can screen the company without opening a single file. Ask whether it is a US business that reached 50+ full-time employees at peak (contractors excluded), has several years of documented history, holds the rights to its own records and has someone with authority to sign. The company fit checker is a preliminary, non-binding screen the owner can run without giving contact details, and how it works explains every stage after the introduction. For firm-side questions, see the referral guide for accountants and the Safeguards Rule guide for CPA firms.

Next step

At your next advisory meeting, ask one eligible client whether they want the introduction, and record their consent before you act. Then register as a partner and send your referral link, so the client applies directly at sourcex.si/apply and nothing leaves your file.