It is written for fractional CFOs, accounting practice leaders and CPAs who see a client's operating history from close up and wonder whether an introduction to SourceX is theirs to make for pay. Pages on single codes and states exist elsewhere on this site; the cross-profession issue register covers networks where people other than accountants could be paid. This page is the accountant's own file, kept client by client.
Two facts decide which rules reach you
Your role toward this company. An outside firm may audit, review or compile its statements, prepare its returns, run its monthly close or advise its CEO. A fractional CFO may sit inside its finance function part time. An accountant may also be its employee, or retired from practice altogether. Each role brings different duties, and a single firm can hold several roles for one client at once.
Where you are licensed and practice. The AICPA's own professional responsibilities page notes that "The vast majority of state boards of accountancy have adopted the AICPA Code of Professional Conduct within their state accountancy laws or have created their own." The same page lists, among the duties of AICPA members, disclosing commission or referral fees to the client, and says conflicts of interest must be disclosed and the client's consent obtained (our paraphrase of the page). So an accountant can be bound by a society's code as a member and by a board's rule as a licensee, and the two need not read alike.
The client's side of the ledger is simpler. An introduction gives its CEO an option, nothing more. SourceX licenses records directly from the company and pays it under its own agreement, and section 4 of the terms says the reward "is paid separately by SourceX and is never deducted from the supplier's agreed compensation." That benefit to the client is real, but it does not settle whether you may be paid. Only the rules do.
Same accountant, two clients; same client, two accountants
Two kinds of restriction need telling apart, because they fail in different ways.
Role-specific: one accountant, different answers for different clients. The facts that vary from client to client:
- the services you or your firm perform for that client, and the periods they cover;
- whether others will rely on a report you issue about it;
- whether you serve it from public practice or as its employee;
- what your engagement letter with it says about outside pay and confidential information.
Jurisdiction-specific: one client, different answers for different accountants. The facts that vary from accountant to accountant:
- which boards license you, and in which states you serve this client;
- which professional bodies you belong to;
- your firm's or employer's policy on outside compensation;
- where you are taxed on what you earn.
A tax-only client and an audit client of the same firm may get different answers. So may two accountants, licensed by different boards, who advise the same company. Neither answer can be borrowed from a colleague's file.
The jurisdiction-and-service review checklist
One copy per client. Each line is a fact you can state without opening a single client record.
| Line | What you write down | Kind of rule it points to | Who answers |
|---|---|---|---|
| 1 | Every service you or your firm performs for this company, from the engagement letters | Commission and referral-fee rules; independence | Your firm's ethics partner, your society's ethics guidance or counsel |
| 2 | The periods those services cover, including statements already reported on | The same | The same |
| 3 | Services proposed or likely within the next year | The same | The same |
| 4 | Each board that licenses you, and each state where you serve this client | Board rules on commissions, referral fees and disclosure | Each board's own published rules |
| 5 | Your status for this client: public practice, employee or retired | Which parts of a code apply | Your society or board |
| 6 | Professional bodies you belong to | Each body's code | That body's ethics guidance |
| 7 | Your firm's or employer's policy on outside pay | Policy | Managing partner or compliance |
| 8 | Your engagement letter and any confidentiality agreement with the company | Contract terms | Counsel |
| 9 | Who you would tell, what, when and in what form | Disclosure and consent | Board, society or counsel |
| 10 | How a reward would be reported for tax | Tax | Your own tax adviser |
Date each answer and keep the name of whoever gave it. An undated "should be fine" from a colleague is not an answer.
Your access to the company's ledger, systems or files exists for the engagement. It is never a way to look at, count or describe records for SourceX. The CEO decides whether the company talks to SourceX at all, and SourceX's screening page lists introductions made without the decision maker's knowledge, and material that belongs to the company's own clients, among the cases that are usually not a fit.
Three moments to run the checklist
- Before SourceX comes up with the CEO. Run all ten lines before the first conversation in which you might mention SourceX as someone who could pay you.
- Whenever your work for the company changes. A new engagement, a proposal, a lender's request for a different kind of report, a move to another firm or a new license: rerun lines 1 to 7.
- Before the reward is payable. Section 5 of the terms ties the payment deadline to two events late in a deal, the Acquisition Partner's final written acceptance of the dataset and its completed handoff, and adds that "payment must also be lawful." Months can separate an introduction from that point. If any line changed in between, ask again before you accept, and if an answer arrives that you may not accept the payment, tell SourceX in writing at once; how the reward is then handled is SourceX's decision.
Participation, independence and pay: questions for your board, society or counsel
Phrase each one with your own facts from the checklist attached. None is answered here.
- Given the services my firm performs for this client, may I accept any payment from a third party for introducing it?
- Does any rule look at services my firm performs for this client, not only my own?
- Does it matter how this payment is classified, and what would my board call it?
- If I may accept it, must I disclose it, to whom, in what form and before what point?
- Does my board's rule differ from the code of the body I belong to, and if so, which governs me here?
- Must my firm or employer approve the payment, share in it or receive it instead of me?
- Would accepting it affect my objectivity on any advice I give this client about a license?
A disclosure is one kind of rule among several. Do not assume that telling the client makes a payment permissible; ask.
A paid path and an unpaid path, both approved by the client
| Path | When it fits | What happens |
|---|---|---|
| Paid | A dated written answer permits it, any required disclosure is made and the CEO wants the introduction | Register, sign the SourceX Channel Partner Agreement, then submit; SourceX decides fit and credit |
| Unpaid, as the published terms allow | You would rather not be paid, or an answer rules pay out | Do not register or submit for this company; tell the CEO SourceX exists and let the company apply on its own |
| Already registered, wanting no reward | The terms do not cover declining a reward | SourceX decides how that is handled; ask SourceX in writing before submitting anything |
| Hold | An answer is still pending | Nothing is submitted in your name; the CEO can apply directly at any time |
On every path the company is paid the same, because the reward never comes out of its payout. Whether even an unpaid mention touches another duty, such as confidentiality or objectivity, is also a question for your adviser. The unpaid routes set out for LPs follow the same published terms.
Three accountants, three files (Illustrative)
Illustrative. Invented accountants and companies; no file describes what any rule says.
A. Tax and advice only. A sole practitioner prepares returns and gives quarterly advice to a 140-person distributor, and holds one state license. Lines 1 to 3 show no other services. She sends her facts to her counsel, receives a dated written answer that permits the payment with written disclosure, gives the disclosure before her conversation with the CEO, registers and signs. The CEO wants the introduction, and the company applies itself.
B. A colleague's engagement. A partner at a regional firm advises the CEO of a 300-person logistics company on systems; another team at the firm reviews the company's financial statements. Line 1 records the firm's review engagement. The firm's ethics partner rules that the firm will accept no reward connected with this client. The partner takes the unpaid path: he tells the CEO SourceX exists and the company applies on its own.
C. The work changes mid-deal. A fractional CFO introduces a 220-person services firm on the strength of a dated written answer that permits the payment. Four months later, a lender asks her firm for a new kind of report on the company. Line 3 changes, so she reruns the checklist before any reward becomes payable and, while the answer is pending, tells SourceX in writing.
What the checklist cannot settle
- It is not advice. Only the rule-maker, or counsel reading the rule for your facts, can say what applies.
- Rules change. Boards and societies revise their rules; date every answer and ask again after a change.
- You may not know every service. Firm-wide engagements can escape an individual's memory; check the firm's conflict records, not your recollection.
- Rule-makers can disagree. Record each answer; you and your counsel decide how to proceed.
- Fit is separate. Even a permitted introduction leaves fit to SourceX's review of the company's size at peak, its own records, its rights and its relevance to a current program.
Method note. The checklist and the three moments were assembled on 2026-10-27 from SourceX's terms in version 2026-10-22.2, since replaced by version 2026-11-04, its screening profile and the AICPA's professional responsibilities page. They organize questions; they interpret no rule, and no figures exist on how often accountants' rules limit rewards in SourceX's program.
Next step
Refer a company. No cap on rewards. Default reward on a company's first qualifying transaction: the greater of $50,000 plus 5% and 15% of Actual Supplier Payout, with no cap; further qualifying transactions first agreed within 12 months of the first Closing pay 15%. Eligibility and payment conditions apply, including the USD 100,000 Minimum Transaction, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.
When a client's checklist carries a dated answer that permits the payment and the CEO wants the conversation, register as a partner, set the company beside the screening criteria and go through the program terms once more before submitting; how the stages run after that is set out in how it works, and more guides are in the guides hub.