How can a commercial banker introduce a data licensing opportunity without tying it to credit?

Can a relationship manager raise data licensing with a borrower?

Yes, as an optional business idea that has no connection to any credit decision, and only after your bank's compliance team confirms how its policies treat outside referral rewards. The idea is simple to state: some companies hold years of operational records that AI developers license, and SourceX manages that process.

The banking-specific risk is not the idea. It is the appearance that credit, pricing or a renewal depends on the client saying yes. Banks operate under federal anti-tying rules that limit conditioning credit on other products or services, and under bank bribery rules that limit what personnel may accept in connection with bank business. This page does not interpret either set of rules, and your compliance team is the authority on how they apply to you. It shows how to structure the conversation so compliance can approve it quickly. This is general information, not legal, tax or financial advice. Confirm with your bank's compliance and legal teams before acting.

Why bankers are well placed, and why that is also the risk

You see covenant packages, annual financials and management meetings that few outside advisors see, and owners tend to treat you as a trusted voice. That same position is why a suggestion from you can feel like a requirement.

Three facts shape everything below:

• The bank, not you, decides whether you may take part in an outside referral program at all.
• A suggestion that arrives in the same email thread as a credit approval reads differently from one made at a separate, non-credit meeting.
• The client's answer must never change how you treat the relationship.

Which clients on your book are worth a mention?

Look for borrowers whose operating history is documented and who are large enough to generate rich records. You can usually judge this from the file you already hold, without asking for any records.

Never use information from the credit file, such as covenant status or financial distress, as a reason for a pitch. If a client is in workout or a special-assets group, leave it alone and see the guidance later on this page.

The keep-it-optional rule: three tests before you say a word

Run these three checks every time. If any fails, do not raise it.

• Approval: has compliance confirmed in writing that you may make this kind of introduction, and under what disclosure terms?
• Separation: can you raise it outside any credit discussion, at least a few weeks away from an approval, renewal, waiver or pricing conversation?
• Silence is safe: if the owner says nothing or says no, will nothing about their loan, deposits or treasury services change, and can you say so out loud?

When in the relationship to bring it up

How the introduction works without the bank touching records

Your role ends at the introduction. You never see, export or describe the client's records.

1. Compliance approves your participation and any disclosure wording.
2. You mention the idea to the owner or CFO in a non-credit setting and hand over a link, not a pitch deck.
3. The owner decides whether to look at the company fit checker or apply directly at sourcex.si/apply.
4. SourceX qualifies the company, helps it build a data inventory, agrees price and terms, and arranges buyer review.
5. If the company signs and the buyer pays, the company receives one all-in price. Nothing is binding until the company agrees terms and signs.

What to say

Say the last two sentences in writing as well. A follow-up email that repeats the optional and unrelated points creates a clean record.

How rewards work, and what to disclose

Partners earn 25% of the eligible platform fees SourceX collects from the referred company's licensing deals, up to $100,000 per referred company, paid after the buyer pays and SourceX receives its fee. The reward is never deducted from the company's proceeds, and no reward is guaranteed.

If your bank permits participation at all, disclose to the client that you may receive a reward before the introduction, in writing. A client who learns of it later may read the whole conversation differently. Whether you or the bank may accept it is a compliance decision, not a program decision. Read the rewards page for how payment works, and see program terms for the partner agreement.

When not to bother

• The bank prohibits outside referral rewards, or compliance has not answered.
• The client is in workout, default or a pending credit decision.
• The borrower is below the 50+ full-time employees at peak baseline (contractors excluded), or its records mainly belong to its own customers without consent.
• You cannot reach an owner, CEO, CFO or authorized representative outside the credit relationship.

Bankers who prefer to hold a client conversation without any reward can still point owners to the program, but the same approval and separation rules apply.

Related reading for advisors in similar spots

Advisors in adjacent roles face the same independence questions. Management consultants deal with scope creep and disclosure, and M&A advisors weigh it against sale mandates. The stakeholder objection map lists the concerns an owner may raise, and how advisors introduce legal services clients shows a parallel approach for another regulated profession. Before you reply to an owner's detailed question, see the delivery manifest template to understand what handover involves.

Next step

Ask compliance first. If it clears you, register as a partner, check the referral earnings calculator to see how the formula works, and read the FAQ before your first conversation.