For a VC portfolio operations lead, divestitures arrive from two directions. A portfolio company sells a business unit to a strategic buyer, or a portfolio company buys a unit that a larger group is shedding. In both, the question that matters is not "which company?" but "which records, and whose yes?"
Why a divestiture strands records away from the people who decide
A divestiture cuts through three things that used to sit together, and each is cut at a different place.
- Ownership is cut by the deal documents. The purchase agreement and its schedules say which records transfer, which the seller keeps and which copies either side may retain. How the sale was structured matters too; asset and stock sales leave records in different hands.
- Custody is cut by the transition plan. A unit often keeps running on the seller's ticketing, ERP or email under a transition services agreement (TSA) long after ownership moved.
- Knowledge is cut by the people plan. The unit's managers usually move with it, but the finance, IT and shared-services staff who built and ran the systems often stay behind.
A regulator-ordered divestiture shows how literally records can be split. In the Federal Trade Commission's decision and order in the Sherwin-Williams and Valspar matter, which covers an industrial wood coatings divestiture, the definition of business records reaches operating and financial records. In paraphrase, where records mix information about the divested business with the business being kept, or where the seller has to keep the originals, the seller hands over only copies or excerpts, redacted as needed, and gives the buyer access to the originals when a copy will not do for evidentiary or regulatory purposes. Commingled history ends up as originals on one side and excerpts on the other, and neither company holds the whole of it.
Find each record set's owner, holder and deciding CEO
Before drawing anything, sort the unit's history into four categories. The sort comes from the company's own account of its separation documents, given by its CEO or someone the CEO points you to; never from a deal file the fund saw through a board seat.
- Travels. Assigned to the unit and now owned by the buyer. The buyer's CEO decides, because once a company or business is acquired, SourceX's screening guidance looks to the acquirer's CEO rather than the former board.
- Stays. Kept by the seller as part of the business it retained. The seller's CEO decides, but only for the seller's own history.
- Shared. One system served both sides, so the records are commingled: originals with one company, excerpts or copies with the other. Each CEO decides only for the part its company holds rights to, and neither can offer the whole set.
- Stranded. The documents do not mention it, or nobody wants it: an old archive on a server neither side migrated. No CEO can decide until counsel says who owns it.
One more test sits outside the four categories. If either side has already licensed a record set for AI training, it is out; SourceX's suppliers confirm their data has not been licensed that way before.
The separated-asset sponsor map
The map has one row per record set and keeps four roles apart that a divestiture tends to blur: the rights holder, the authorizer, the holder and the insider. A fifth column records the path, meaning the person in your network who can ask the authorizer and be heard.
| Record set | Category | Rights holder after closing | Authorizer | Holder today | Insider who can explain it | Path from your network | Status |
|---|---|---|---|---|---|---|---|
| Name the system and years | Travels, stays, shared or stranded | The entity the documents assign it to | That entity's CEO | Whose systems or tenant | Someone who ran it, and where they work now | The colleague who can ask the authorizer | Confirmed, estimate or unknown, with a date |
Filled in for a fictional deal, it looks like this.
Illustrative. A portfolio company, a 600-person facilities-services group, sold its 140-person building-monitoring unit to a strategic buyer. Closing was on 2026-08-31, and the seller hosts the unit's systems under a TSA until 2027-02-28. The fund's board member at the seller still talks to the seller's CEO every month; the unit's general manager, who now reports to the buyer's CEO, worked with the fund's platform lead for years.
| Record set | Category | Rights holder after closing | Authorizer | Holder today | Insider who can explain it | Path from your network | Status |
|---|---|---|---|---|---|---|---|
| Unit's alarm and dispatch tickets, 2015 onward | Travels | The buyer's subsidiary that took the unit | The buyer's CEO | The seller's ticketing system, until TSA exit | The unit's operations manager, now at the buyer | The unit's general manager | Rights confirmed by the seller's CEO; buyer not yet asked |
| Payables, receivables and job costing in one shared ERP | Shared | Seller keeps originals; unit receives an excerpt of its own entries | Each CEO, for its own part only | The seller's ERP | A seller finance lead | The fund's board member at the seller, for the seller's part | Excerpt scope unknown |
| Field-service procedures written for both businesses | Stays | The seller | The seller's CEO | The seller's document system | The seller's quality manager | The fund's board member | Confirmed; whether the unit took a copy for its own use is unknown |
| Unit's 2012 to 2014 archive on a retired server | Stranded | Not named in the schedules | None until counsel decides | A server in the seller's back office | Nobody still employed | None | Stop |
Read the map row by row, not company by company. The seller's row is ready: the board member can ask its CEO about the procedures and the seller's own share of the ERP. The tickets row waits for the buyer's CEO, reached through the general manager. The ERP row cannot be offered as one dataset by anyone. The server row stops.
Method note. The four categories and the roles are an editorial structure built on SourceX's screening guidance and program terms, both checked on 2026-10-27, and on the FTC order described above. The map measures who decides and who can ask. It does not assess record quality, demand or rights; those are settled in SourceX's review and the agreement the company signs.
The transition events that move each column
Four dates move different columns of the map, so date them first.
- Signing. The purchase agreement, its records schedule and the TSA are agreed. Until closing the seller's CEO still decides for the whole company, unit included, within whatever limits the agreement puts on new commitments.
- Closing. The authorizer column flips to the buyer's CEO for every row marked travels. Nothing else moves that day: the records still sit where they did.
- TSA exit. The holder column flips. The unit's history is exported to the buyer or left behind, and the seller may wipe its copy as the agreement requires. Ask for each system's export date and whether the export was checked.
- A claim or an order. An indemnity dispute under the purchase agreement can put records under a legal hold, and in a regulator-ordered divestiture the order itself governs which records the buyer receives and what the seller keeps. Either one overrides everything else on the map until counsel releases it.
Throughout, nobody in the referral touches records, requests samples or asks for a switch-off to be delayed so an introduction can happen. Preservation belongs to the companies and their counsel. Real timing comes from those documented dates, not from a referral's convenience; the TSA expiry checklist lists what to confirm before a service ends.
Pick a window for each row, or stop
Decide per row, after the authorizer for that row has answered, and write the date on the map.
- Travels. After closing, through a live path to the buyer's CEO, and ideally before TSA exit so the export is confirmed while the people who know the records are still on hand. If nobody in your network can reach the buyer's CEO, stop.
- Stays. Any time the seller's CEO wants the conversation. Copies of the unit's history that the seller kept for tax or legal reasons stay out unless the separation documents gave the seller a right to license them, and SourceX's rights review tests even that.
- Shared. Wait until the excerpt is cut. Then each company can discuss only its own part, and each part is screened on its own merits.
- Stranded. Stop and record why. Counsel may later assign the archive, and the row can come back with a named owner.
The fit facts apply to whichever company would license: 50+ full-time employees at its peak, contractors excluded, documented operating history, the rights to license and a CEO who wants the conversation. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 70% of the data is in English.
Credit works as it does for any company, which means you should time the introduction to when the company can apply rather than to TSA exit. Under section 2 of the program terms, "The first valid introduction of a new company within the 90-day attribution window receives credit when that company submits a verified application." After closing, the seller and the unit are different companies in different groups. Each referred company's first qualifying transaction carries its own USD 50,000 floor, once per company and never again on a repeat, so the unit and the seller are counted separately and neither has a cap; the subsidiary floor guide explains how subsidiaries are counted. Whether the seller's earlier dealings with SourceX, or another partner's introduction of a company in the buyer's group, change who is credited for the unit is not answered in the terms. SourceX works that out in its duplicate review, from dated records, and nobody should promise a result in advance.
Five ways a separated-asset map points the wrong way
- It maps claims, not documents. Every rights cell is the company's account of its own deal. Mark as an estimate anything the rights holder has not confirmed.
- Orders and agreements differ. The FTC example shows one order's approach to commingled records; a private purchase agreement can allocate them differently, and only the companies' counsel can read it.
- Insiders leave. The person who can explain a record set may be gone by TSA exit. Date every insider entry and expect it to go stale.
- Rights and demand are unknown. Customer contracts, employee privacy and third-party terms can narrow any row, and whether a record set matches a current program is decided in SourceX's review.
- Relationship cost. Asking a unit's new leadership about data licensing in their first months under a new owner spends goodwill. No published data shows how often that works; record what happens.
A measurable next step. For the next divestiture in or around the portfolio, fill in one map within two weeks of closing. Count rows marked ready, waiting and stopped, and recount at TSA exit. If most rows are still waiting at exit, start the map at signing next time. SourceX has not published how many divested units are introduced or accepted.
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 row on your map has a confirmed rights holder, a CEO who wants the conversation and a dated holder, create your partner account, check that company against who qualifies and read the terms before anyone writes to it. The seller's side of the work is in the divestiture checklist and the advisor's view in the program for divestiture advisors; revisiting an older referral after a separation is covered in carve-out data separation, exit authority in who can authorize after a portfolio exit, and more in the guides hub.
Mapping a divestiture for referrals is one decision; judging SourceX as a company to invest in is another, and readers weighing the second can request investor materials from the SourceX investor overview.
This article is for information only and is not an offer to sell or a solicitation of an offer to buy securities. Any offering by SourceX is made only to verified accredited investors through its offering documents.