AICPA conflicts of interest: what a CPA must do when an introduction pays

A paid introduction is a self-interest threat under the AICPA conflicts of interest interpretation, so a CPA must identify and evaluate it, then apply safeguards, disclose and obtain client consent, or decline. Keep the owner in charge of the decision, introduce only companies that fit the published criteria, and document everything in the client file.

Is being paid for an introduction a conflict of interest for a CPA?

It can be, because a reward that depends on a client's decision gives the firm a financial stake in advice it is supposed to give objectively. That is a self-interest threat, and the AICPA conflicts of interest interpretation (commonly cited as ET 1.110.010) expects a member to identify the threat, evaluate how significant it is, and then apply safeguards, disclose and obtain consent, or decline.

The SourceX program does not change the analysis. It gives you a concrete fact pattern to run it on: your firm introduces a client, and if that client licenses data and the deal is paid, the firm may be offered a reward.

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

What the conflicts interpretation asks you to do

Read the current text in the AICPA Code of Professional Conduct, which is a pointer to the rule; the AICPA's online Code is authoritative for the version in force. In plain terms, the interpretation walks through four moves.

Identify the relationship or interest that could be seen as competing with the client's interest. Here it is the possible reward.
Evaluate whether a reasonable and informed third party would think your objectivity is compromised, given the size of your role in the decision.
Address a significant threat with safeguards, or by disclosing it and getting the client's consent, or by declining the introduction.
Document what you concluded and why.

Two neighbouring rules matter just as much. The contingent fee rule tests fees your client pays you, and the commissions and referral fees rule (1.520) tests payments from third parties. Florida shows how far state law can go: its statute on CPA commissions and referral fees restricts accepting or paying referral fees for certain services and requires written disclosure of commissions. Check the version in force where you are licensed.

How the threat shows up in common CPA situations

Situation	What to check	Outcome to confirm with your ethics counsel
Client is an audit or review client	Whether 1.520 bars accepting any reward for that client	Often a decline or waiver; see the page on attest clients
Client receives only tax or advisory services	Whether the threat is significant, and whether disclosure and consent are needed	Typically disclose in writing and obtain consent before the introduction
You are the client's day-to-day CFO or controller	Whether you are effectively making the decision, not advising on it	Safeguards are harder; consider referring the reward to the firm's policy or declining
The reward would go to a partner personally	Whether firm policy and state rules treat it as a firm matter	Route through firm policy; see partner versus firm
You know the client is under the published baseline	Whether recommending anyway serves the client or only the reward	Do not introduce; it fails the objectivity test on its face
State board is stricter than the AICPA	Statute or rule text in your state, such as the California rules	Follow the stricter rule

Safeguards that make an introduction easier to defend

The owner decides. Your role is to say that a program exists, explain the published criteria, and step back. These safeguards are the ones reviewers tend to look for.

Fit-only recommendations. Introduce only companies that meet SourceX's published baseline: 50+ full-time employees at peak (contractors excluded), several years of documented operations, rights to license the data and an authorized sponsor. Run the company fit checker with the client first.
No role in the deal. Do not select data, set price, negotiate terms or sign for the client. A partner only makes the introduction and gives basic fit information.
No confidential records. Never export, upload or describe client records to SourceX. The company works with SourceX directly.
Written disclosure. Tell the client in writing that the firm may receive a reward if a deal completes, and that the reward is a share of SourceX's fee and is not deducted from what the client receives.
Independent advice. Suggest the client take its own legal advice on the license.

What to keep in the client file

The engagement type and whether the firm performs attest services for this client
Your written evaluation of the self-interest threat and the conclusion reached
The state board rule or statute you checked, with the date
The client's written disclosure and consent, or the reason none was needed
A note that the firm took no part in data selection, price or contract terms
The firm's internal approval, for example from the ethics or risk partner
A record of any reward declined or waived

What to say to the client

How rewards work

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 comes out of SourceX's fee, it is never deducted from what the company receives. Whether your firm may accept it at all is a question for your professional rules, not for the program; read the program terms and rewards page and decline or waive if your rules require it.

When not to introduce

The firm audits or reviews the company and your rules bar the reward, and you are unwilling to waive it.
The relationship is so close that the client would struggle to say no.
The company is below the published baseline or its data mostly belongs to its own clients.
Your state board, employer or insurer has not cleared the arrangement.

Questions to ask your ethics counsel

Does my state board adopt the AICPA conflicts interpretation as written, or has it added its own disclosure or consent requirement?
Is a reward received by the firm treated differently from one received by an individual partner?
Does the firm's quality control policy require approval from a designated partner before any third-party compensation is accepted?
Would our professional liability insurer expect to hear about the arrangement?
If the client later disputes the license terms, how do we show that we kept out of the negotiation?

A worked example

Illustrative: a regional firm provides tax and fractional CFO services to a 120-person logistics company. The firm is not its auditor. The ethics partner identifies the reward as a self-interest threat, notes that the firm's CFO role makes the client likely to follow its lead, and so requires three things: a written disclosure, a fit check against the published criteria, and a rule that a different partner handles any follow-up questions from the client. The memo records the date, the state rule consulted and the decision to proceed. If the same company were an audit client, the memo would instead start with the referral fees rule and likely end with a decline.

Next step

Write the one-page threat evaluation for your firm first, then register as a partner if the conclusion is to proceed. Accountants who want the wider picture can start with the accountant referral overview.

Step 1Share your linkSend your personal link to a company you know.
Step 2Company appliesThe company applies itself at /apply.
Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Does the conflicts rule apply even if the client is not an attest client?

Yes. The conflicts of interest interpretation covers any professional service, so a tax, advisory or accounting client still triggers the analysis. Attest status adds a second layer, the commissions and referral fees rule, which can bar the reward outright. Run both checks and record the conclusion for each before introducing anyone.

Is written consent always required?

Not always. Where you conclude the threat is not significant, or safeguards reduce it to an acceptable level, consent may not be required. Many firms still disclose in writing as a matter of policy because it is cheap and easy to evidence. Your ethics counsel and state board decide the minimum for your firm.

Can the firm just decline the reward and still introduce the client?

Declining or waiving the reward removes the financial interest that creates the threat, which is often the cleanest route. You should still document the decision and check whether the introduction itself raises other concerns, such as independence for attest clients. Confirm the approach with your ethics partner.

What should the disclosure say?

It should state that the firm may receive a reward from the program operator if the client licenses data and the deal is paid, that the reward is a share of the operator's fee and not deducted from the client's proceeds, and that the client is free to decline and to seek independent legal advice. Keep it short and plain.

Do state boards follow the AICPA wording?

Some adopt the AICPA provisions by reference and others write their own statutes or rules, which can be stricter. Florida regulates commissions and referral fees by statute, for example. Check the rule where each CPA is licensed, because the state rule controls if it is stricter than the Code.

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By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09

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