This page gives no legal or professional-conduct advice. It sets out what the draft should contain and who should read it. Whether your rules allow a reward at all is the separate check on the accountant's service-and-jurisdiction review; this page starts once you need words on paper.
Why the draft goes to a reviewer before it reaches the client
Two published rules show why a disclosure written from instinct is not enough. They are examples of what to ask about, not a statement of what applies to you.
A role-specific duty. CFP Board's Code of Ethics and Standards of Conduct requires a CFP professional who provides Financial Advice to make "full disclosure of all Material Conflicts of Interest" with "sufficiently specific facts" for a reasonable client to understand them and consent or say no. The same standard, as we read the excerpt, treats disclosure and consent as only part of the duty: business practices must also be designed to keep a material conflict from compromising the professional's ability to act in the client's best interests. Whether an introduction to SourceX counts as Financial Advice for that purpose is a question for CFP Board's guidance or your counsel.
A jurisdiction-specific bar. California's Accountancy Act, which the California Board of Accountancy publishes, bars a licensee from accepting a fee or commission for referring a client to a third party except as section 5061 permits, and does not permit accepting a commission solely for the referral of a client (our paraphrase). For a California licensee, then, a reward for an introduction alone may be something no disclosure can make acceptable. That reading is for the Board's rules and your counsel to confirm.
SourceX's documents leave this to you. Section 5 of the terms says "payment must also be lawful," and the sample Channel Partner Agreement we read sets no wording for a partner's disclosure to its own clients.
The professional-review disclosure checklist
Twelve items in three groups. The wording column is a starting draft for your reviewer to change, not approved language.
| # | The item | Starting wording for review | What it rests on |
|---|---|---|---|
| 1 | Who may pay you | "SourceX may pay me a referral reward if your company licenses data to SourceX after my introduction." | Terms, section 4 |
| 2 | On what basis | "By default the reward is the greater of $50,000 plus 5% and 15% of what SourceX actually pays the company, with no cap for the company and its corporate group." | Terms, section 4; one cap per group |
| 3 | When, if ever | "Only if the company completes a qualifying, paid licensing deal and the conditions in SourceX's terms are met. An introduction, a meeting or a signature earns nothing." | Terms, section 5 |
| 4 | The company's payout | "SourceX pays any reward separately and never deducts it from what your company is paid, so the company receives the same amount with or without me." | Terms, section 4 |
| 5 | No promise | "There may be no deal and no reward. I cannot predict either, and any estimate SourceX shows is not a promise." | Terms, section 5 |
| 6 | What you will do | "I will make one introduction to the contact you choose, with only the details you approve." | Your engagement |
| 7 | What you will not do | "I will not look at, export, summarize or send company records to SourceX, negotiate for the company or sign anything." | Partner agreement, section 4.2 |
| 8 | Who decides | "Whether to apply, and every decision after that, is yours as CEO." | SourceX's screening page |
| 9 | Your interest | "Because I may be paid, my view on whether to go ahead is not independent. Ask someone without that interest if you want a second view." | Your conflict |
| 10 | You do not speak for SourceX | "I am not SourceX's agent and cannot commit it to anything." | Partner agreement, section 7.1 |
| 11 | The route without you | "You can apply to SourceX directly, and declining my introduction changes nothing in our engagement." | The company's own choice |
| 12 | The reviewer's record | Reviewer's name and role, the date, the rule relied on, and any form, timing or signature they require | Your file |
Items 2 and 3 do most of the work: they turn "a fee" into a basis and a condition the client can check against the program terms. Item 9 is the one advisers most often leave out, and the one a client most needs.
Which reviewer reads it, by role and by place
| Your situation with this client | Who reviews the draft | What to ask them |
|---|---|---|
| CPA in public practice, no attest work for the client | Your board's published rules, your society's ethics guidance or counsel | Whether a reward is allowed, and what form, timing and recipient the disclosure needs |
| Your firm performs audit, review or other attest work for the client | Your firm's ethics partner, then the board's rules or counsel | Whether any reward or even an unpaid mention fits independence |
| Licensed in a state with its own accountancy act, such as California | That board's published act and rules, read with counsel | Whether pay for an introduction alone is permitted at all |
| CFP professional | CFP Board's standards and compliance resources, or counsel | Whether the introduction is Financial Advice and how the conflict must be disclosed and managed |
| Fractional CFO who signs for the company or approves its payments | Counsel, and the company's board if your contract requires it | Whether taking a reward is compatible with the role at all |
| Employee of an advisory or accounting firm | Your firm's compliance lead or managing partner | Whether the firm allows it, and whether the firm or you would be the partner |
| Adviser with no professional license | Your contract with the client and your own counsel | What your engagement terms say about outside pay and confidentiality |
When several of these apply, ask each. The cross-profession issue register keeps one row per person who could be paid, and restructuring roles have their own page on referral fee disclosure for restructuring professionals.
When the reviewer rules out pay
Use a shorter disclosure and the unpaid route. Something like: "I am not accepting anything from SourceX for this. If the idea interests you, your company can apply directly, and nothing in our engagement changes either way." Do not register or submit for this company; tell the CEO SourceX exists and let the company apply on its own. Even an unpaid mention can touch confidentiality or objectivity, so ask your reviewer about that too. If you are already registered and want no reward for one client, the terms do not cover declining, so SourceX decides how it is handled; ask it in writing before anything is submitted.
From draft to introduction, in order
- Draft the twelve items for this client.
- Send the draft to every reviewer your situation calls for, and record each answer with a date.
- Revise, then give the client the reviewed version, in whatever form and at whatever time the review requires, before SourceX comes up as a possible payer.
- Let the CEO decide. A no ends it; record the date.
- On a yes, register, sign the SourceX Channel Partner Agreement and submit the introduction.
- Review again when your services, your license or your firm change, or before a reward becomes payable, as the accountant's three checkpoints describe.
One draft, before and after review (Illustrative)
Illustrative. An invented fractional CFO, also a CFP professional, drafting for an invented 150-person logistics client.
| First draft | Reviewer's note | Revised line |
|---|---|---|
| "SourceX pays a small finder's fee." | "Small" hides the basis | "By default the reward is the greater of $50,000 plus 5% and 15% of what SourceX actually pays the company, with no cap." |
| "Your data could bring in a significant payment." | A forecast nobody can make | "SourceX first gives an indicative estimate; any payout is fixed only in a signed Dataset Deal Confirmation between your company and SourceX." |
| "I'll handle the details with SourceX for you." | Implies records and negotiation | "Your company deals with SourceX directly; I make the introduction only." |
| "The fee does not affect my advice." | An assertion, not a disclosure | "Because I may be paid, my view on whether to go ahead is not independent." |
| Nothing about an alternative | The client needs a route without you | "You can apply directly, and saying no changes nothing between us." |
The revised version is longer and less comfortable to send. It is also the only one a reviewer, or the client, could check line by line.
What the company must bring, whatever the disclosure says
A disclosure describes your interest; it says nothing about whether the company fits, and it must never imply that it does. SourceX screens on full-time headcount at peak (50 or more, contractors excluded), years of records the company created itself, its rights to license them and a CEO who authorizes the discussion, and it checks relevance to a current program in review. SourceX's screening page also counts an introduction the decision maker never knew about among the poor fits, which is one more reason the CEO reads the disclosure first. How to talk about the money without turning it into a forecast is covered in describing referral economics without forecasting.
Limits of a reviewed disclosure
- It is not permission. A reviewer can say a disclosure is needed and still conclude that no reward may be accepted.
- It covers your rules, not the client's. The company's own obligations, including what it may license, are for its CEO, its counsel and SourceX's rights review.
- Rules and roles change. A disclosure reviewed for tax work may not survive a new engagement; date it and review it again.
- Tax is separate. How a reward is reported is a question for your own tax adviser.
Method note. The checklist was built on 2026-10-27 from SourceX's terms (version 2026-10-22.2, since replaced by version 2026-11-04), its screening page and its partner agreement sample, with CFP Board's Standard A.5 and California's Accountancy Act as examples of a role-specific and a jurisdiction-specific rule. It interprets neither rule, and no data exists on how clients respond to reviewed disclosures 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.
Once a reviewer has marked your draft and the CEO has read it and wants the conversation, register as a partner, test the company against who qualifies and read the program terms before submitting; an archive review that raises the question has its own page, and more is in the guides hub.