How CAS teams screen attest clients before a compensated introduction

Before any compensated introduction, a CAS team should confirm whether the firm performs an audit, review, certain compilations or an examination of prospective financial information for the client, because the AICPA Code bars commissions for those clients and requires disclosure of permitted ones. Then check the state board rule, disclose in writing, obtain consent and document the file.

Why CAS teams need a written screen

Client accounting services teams sit closest to owners, closes and systems, so they are often the first to notice a company that could license its operational records. They also work inside a firm that may audit, review or compile for the same client. A compensated introduction made without checking that relationship can create an independence or fee-rule problem that outlasts any deal.

The fix is a short, repeatable screen run before every introduction, the same way the firm already runs client acceptance and continuance. It takes the question out of individual judgment and leaves a file the ethics partner can review quickly.

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

What do the AICPA rules actually say?

Two sections of the AICPA Code of Professional Conduct matter most. Under the Commissions and Referral Fees Rule (ET 1.520), 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. Where commissions and referral fees are permitted, they must be disclosed to the client.

The Contingent Fees Rule (ET 1.510) is the second check. As the NYSSCPA explains, 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 for whom the firm performs an audit or review, certain compilations, or an examination of prospective financial information. A partner reward paid only if a licensing deal closes is worth putting in front of your ethics adviser under both rules.

Whether a third party's reward for an introduction counts as a commission, a referral fee or something else is a classification question for your ethics counsel. The cautious working assumption is to screen as if the commission prohibition applies until someone qualified tells you otherwise.

Why state boards can change the answer

The AICPA Code is the starting point, not the last word. Your license comes from a state board, and states handle referral compensation differently:

Adoption by reference. Kansas regulation 74-5-103 requires each CPA or firm to comply with the AICPA provisions on commissions and referral fees, including interpretations.
A separate statute. Florida Statutes 473.3205 regulates contingent fees, commissions and referral fees directly, including written disclosure of commissions; the linked page is the 2017 text, so check the current version.
Stricter local rules. The NJCPA overview of commissions and contingent fees shows a state whose rules differ from, and can be stricter than, the AICPA Code.

If the firm audits companies registered with the SEC, the SEC's own auditor-independence rules are a separate regime. Staff correspondence with the AICPA ethics committee on contingent fees is a reminder that the two sets of rules are not interchangeable.

The five-part screen

Run all five parts for each client before anything is submitted, and keep the completed list in the client file.

1. Attest status

Confirm whether the firm performs an audit, review, examination of prospective financial information, or a compilation a third party may rely on, for this client.
Check affiliates, related entities and any network firm that serves them.
Check signed engagement letters for the coming period, not only the current one.
Note whether the period covered by those financial statements could overlap with the date a reward might be paid.

2. Rule check

Read the current text of ET 1.520 and ET 1.510 rather than a summary.
Look up your state board's rule and record whether it adopts the AICPA by reference, uses its own statute or is stricter.
Repeat the lookup for each state where the engagement partner is licensed or the client is based.
Check firm policy, which may prohibit outside referral compensation altogether.

3. Disclosure

Draft a written disclosure telling the client the firm may receive a share of SourceX's fee if a license closes.
State that the reward comes out of SourceX's fee and is never deducted from what the company receives.
Describe the basis without typing amounts: a share of eligible platform fees, capped per company, as set out in the program terms.

4. Consent

Get written agreement to the introduction from the owner or another authorized sponsor.
Limit what is shared to basic fit information: company name, approximate size and the sponsor's contact details.
Confirm that no client records, exports or descriptions of confidential data will leave the firm.

5. Documentation

Write a short memo covering attest status, rules reviewed, sign-off by the ethics or risk partner, and the date.
File the disclosure and the consent with the memo.
Diary a re-check in case the client later engages the firm for an attest service.

How to read the result

Result	What it means	Next action
Current or planned attest client	The commission prohibition is likely to apply	No compensated introduction; ask your ethics adviser whether any introduction is appropriate
Non-attest client, state follows the AICPA	The rule turns on disclosure rather than prohibition	Confirm with your ethics adviser, then disclose in writing, get consent, file the memo and introduce
Non-attest client, state has its own statute	The state may set different conditions	Follow the stricter rule and confirm with counsel
Affiliate audited, or status unclear	Independence questions are unresolved	Escalate to the ethics partner before any contact with SourceX
Firm policy bars outside compensation	The firm has already decided	No compensated introduction; read the program terms before deciding anything else

How the introduction works once the screen is clear

Send the owner your referral link, which opens sourcex.si/apply with your code attached, or submit the company through the referral form.
SourceX checks fit with the sponsor: a US company with 50+ full-time employees at peak (contractors excluded), years of documented operations, a breadth of systems and rights to license.
The company completes its own data inventory of systems, history and export options; as the referrer, your firm stays out of the records.
Price and terms are agreed with the company before buyers review the opportunity.
AI labs and data buyers review it, and the company signs only if the terms work.
Data is delivered under the agreed redaction rules after an executed agreement, and the company is paid.
Any partner reward follows once SourceX has received its fee.

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, paid only after the buyer pays and SourceX receives its fee; no reward is guaranteed. The full conditions are in the program terms.

Red flags that stop the screen

The client is an attest client of the firm or a network firm, or will be during the relevant coverage period.
The owner asks your team to describe or send their records to SourceX on the company's behalf.
The records mainly belong to the client's own customers, as at outsourcers and agencies.
Nobody with authority, such as the owner, CEO, CFO or an authorized representative, will sponsor the decision.
The state rule is unclear and nobody at the firm owns the answer.

Where this fits in a CAS practice

The screen works best as part of the shift from compliance work to advisory, when the CAS lead is already reviewing systems, closes and owner priorities; the guide on moving clients from compliance to advisory covers that shift. Fractional finance leaders face the same questions from a different seat, set out in the referral program for fractional controllers and the page for fractional CFOs. Tax practices can compare notes with the referral program for tax advisors.

Next step

Build the five-part screen into your engagement workflow, then run one non-attest client through the company fit checker. When a client clears both, register as a partner and make the introduction with the owner's written consent.

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 a bookkeeping-only CAS client count as an attest client?

Not by itself. Bookkeeping, outsourced controller work and tax preparation are not attest services. The client becomes an attest client if the firm or a network firm also performs an audit, a review, an examination of prospective financial information or a compilation a third party may rely on, including for affiliates or planned engagements, so check those before treating the client as clear.

Is a SourceX partner reward a commission or a referral fee under the AICPA Code?

That is a classification question for your ethics counsel and state board, not one to settle alone. Because the commission prohibition for attest clients is the stricter outcome, the cautious approach is to screen as if it applies, disclose any compensation in writing to non-attest clients, and record who reviewed the question and what they concluded.

Who in the firm should sign off on the screen?

Whoever owns ethics and independence for the firm: an ethics or risk management partner in larger firms, or the managing partner in smaller ones. The CAS lead runs the checklist, but sign-off should come from someone who sees the whole client relationship, including any audit, review or compilation work handled by another team.

What happens if the client becomes an attest client after the introduction?

Re-run the screen immediately. A reward is paid only after the buyer pays and SourceX receives its fee, which can be months after the introduction, so the timing may overlap with a new attest engagement and the period its financial statements cover. Raise it with your ethics adviser before accepting the engagement or any payment.

Do we need the client's consent before mentioning them to SourceX?

Treat consent as required. Share nothing until the owner or another authorized sponsor agrees, and even then share only basic fit information. The cleanest route is to send the owner your referral link so the company applies itself at sourcex.si/apply; your credit is preserved through the referral code and no client information passes through the firm.

Do these rules apply to accountants outside the US?

The AICPA Code and state board rules govern US CPAs. Accountants elsewhere follow their own professional body's rules on commissions, referral fees and independence, which may be stricter. Anyone in a supported country can join as a partner, but every company introduced must be a US business, so check both your own rules and the program terms.

Free resources

Due diligence checklist generator — A tailored document request list by deal type.
Cash flow calculator — A 12-month cash forecast with shortfalls highlighted.
Referral earnings calculator — Hypothetical partner earnings with the per-company cap.
All free tools · MCP resource center

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

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