SBA Form 159 and referral agents: does it cover data introductions?

Does SBA Form 159 cover a data licensing introduction?

Short answer: Form 159 is an SBA disclosure form about compensation connected to an SBA loan, so an introduction to a separate data licensing service is a different activity that the form does not appear designed to address. But "appears" is not a compliance conclusion. Your lender's compliance team, not this page, decides how your institution treats outside referral arrangements.

This page is for SBA lending staff, lender service providers and loan packagers who are asked whether they can introduce a borrower to SourceX. It explains the logic of the form at a general level, shows how common situations usually need to be checked, and gives questions to take to compliance. This is general information, not legal, tax or financial advice. Confirm with your own counsel, compliance officer or the SBA before acting.

What is Form 159 about, in plain terms?

Form 159 is the SBA's fee disclosure and compensation agreement form. As generally understood, its job is to put on record what an agent, such as a loan packager or consultant, is paid in connection with an SBA-guaranteed loan, so the lender and SBA can see who received what. The rules that govern when it is required, who counts as an agent and what fees are allowed are set out by the SBA in its loan program rules and procedures, which change over time. Read the current form and the SBA's current loan program procedures on sba.gov rather than relying on a summary, including this one.

The key phrase is "in connection with an SBA loan". The form is tied to loan activity, loan applications and the compensation connected to them.

How is a data licensing introduction different?

A SourceX introduction does not involve a loan application, a lender's credit decision or SBA-guaranteed proceeds. The company, if it qualifies, licenses its operational records to AI labs and data buyers, and receives one all-in price. The partner reward is a share of SourceX's fee and is never deducted from what the company receives. Nothing about it is financed by, or conditioned on, an SBA loan.

That separation can be blurred in practice. The table shows common situations and what to check.

What does the borrower need to know?

Good practice is to be open about the arrangement. If you introduce a borrower and may earn a reward, say so in plain words, and let them apply directly through sourcex.si/apply if they prefer not to go through your referral link. Never imply that the introduction affects loan approval, pricing or servicing. Never make it a condition of anything.

What should you ask your compliance team?

• Does our institution allow staff to participate in an outside referral program at all?
• Does our written policy treat a referral to a non-lending service as an outside business activity needing approval?
• If I am a loan packager or lender service provider, do my agreements with lenders restrict other paid referrals to the same borrower?
• Should the introduction wait until after the loan has closed or been serviced for a set period?
• Do we need written sign-off, and who keeps it?
• Are there state rules that apply to us as a bank, credit union or non-bank lender?

Which companies from a lending portfolio are even eligible?

The baseline is a US company with 50+ full-time employees at peak (contractors excluded), several years of documented operations, rights to license the data and an authorized sponsor. Many SBA borrowers are smaller than that: the SBA Office of Advocacy's 2026 small business FAQ defines a small business, for research purposes, as an independent business with fewer than 500 employees, a range that includes a great many firms well below the baseline. A lender's portfolio therefore needs screening, not a blanket pitch. Larger borrowers in logistics, professional services, healthcare administration without protected health information, or financial services may fit. The records must belong to the company; client or consumer data without consent is a red flag.

What are the red flags in this setting?

• The borrower feels pressured because you hold their loan.
• Compensation from SourceX and from the loan are bundled in one conversation or one document.
• The borrower's records are mostly personal information about consumers or clients with no licensing basis.
• You are an employee whose policy bars outside paid referrals.

If any of these apply, a polite decline is often the right answer; see how to decline an introduction request.

How do rewards work, and where do other professionals stand?

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 becomes payable only after the buyer pays and SourceX receives its fee; a lead, meeting or signed agreement alone does not trigger payment, and no reward is guaranteed. Other regulated groups face different questions; for example, insurance agents have their own licensing and referral-fee considerations, and a director's introduction raises corporate opportunity questions. The quality of earnings referral page covers a neighboring adviser group.

Next step

Take the checklist above to your compliance contact before you introduce anyone. If you get written approval, register as a partner, or start with the network opportunity finder to consider which relationships are suitable. Check the who qualifies page for the company baseline. Confirm with your own counsel, compliance officer or the SBA before acting.