# Ownership transition referral handoff: a packet | SourceX

Canonical: https://refer.sourcex.si/guides/the-data-referral-handoff-between-old-and-new-owners
Last updated: 2026-11-05

When a portfolio company changes owners, a data referral survives as dated facts, never as permission. Split the handoff in two. A company copy, kept by the CEO and passed to the new owners in the ordinary course of the sale, records what was discussed with SourceX, which records were described, which duties apply and the decision now waiting. A partner file, kept by whoever submitted the introduction, holds the dated introduction and the signed agreement. After closing, the acquirer's CEO decides whether anything continues.

A VC portfolio operations lead meets this when a sale lands in the middle of a conversation the fund helped start. The founder who said yes is leaving, a buyer's integration team is arriving, and each fact behind the referral is about to change hands on a different date. The packet keeps those facts straight without moving anything the fund has no right to move.

## Which ownership changes move the yes, and which only move the shareholders

Not every change of owner changes who decides. Read the deal structure first.

| Change | Who decides afterward | Where the records end up | What the packet does |
|---|---|---|---|
| Stock sale to a strategic buyer | The acquirer's CEO | Still in the company, now inside the buyer's group | The company copy reaches the acquirer's CEO through the company |
| Sale to another fund through a holding company | The acquirer's CEO, meaning the chief executive of the acquiring group, whom the company names | Still in the company | As above; confirm the name in writing rather than assuming it |
| Asset sale | The buyer's CEO, for the assets and records it bought | Wherever the purchase agreement puts them; the seller may keep excluded records and copies | The seller's CEO decides whether the company copy goes to the buyer |
| Sale of the fund's minority stake only | The company's CEO, unchanged | Unchanged | The company copy stays put; the fund's partner file closes or passes to whoever keeps the relationship |
| Founder or management buyback | The company's CEO, usually the founder | Unchanged | Covered in [the questions around a founder buyback](/guides/the-referral-questions-around-a-founder-buyback) |

SourceX's screening page states the rule behind the first three rows: "Once a company is acquired, the acquirer's CEO decides for it, not the former board." The fourth row is easy to overlook. A secondary sale of the fund's shares changes who sits on the cap table and who holds a board seat, but if the company's CEO stays, the decision stays with that CEO and the referral needs no handoff at all, only an update to the partner file.

The asset-sale row needs the most care with records. U.S. tax rules treat business records as an asset in their own right: Treasury's regulation on amortizing acquired intangibles, 26 CFR 1.197-2, counts an information base among section 197 intangibles and includes business books and records, operating systems and customer information within it. Whether a particular archive went to the buyer or stayed with the seller is answered by the purchase agreement, which counsel reads; [asset and stock sales](/compare/asset-sale-vs-stock-sale-data-ownership) compares the two structures.

## Locating the records and the person who now decides

After a sale, copies of a company's history can sit in four places, and only one of them is the source.

1. **The company's own systems**, or the buyer's after integration. A licensing conversation only ever draws on these.
2. **The data room archive**, often kept by the seller's advisers or the data room provider after closing. It holds diligence copies.
3. **Former directors' board packs**, including the fund's. They are confidential, and they stay with whoever holds them.
4. **The seller's retained copies**, kept for tax filings or purchase-agreement claims.

Copies 2 to 4 exist for reasons that have nothing to do with licensing, and none of them is offered, described or used to answer a question about the records. The decision-maker is found the same way the records are: name the legal entity that holds the records after closing and its CEO, with the date the company confirmed both.

Personal data adds its own sequence. The UK regulator's data sharing code says that where a merger or acquisition means data must move to a different or additional controller, "you must consider data sharing as part of the due diligence you carry out when taking on the organisation and its obligations." The buyer works out the purposes and lawful basis for what it took on. Those obligations, and any duty to preserve records that the deal created, come before any data conversation, and counsel states them.

## The owner transition packet

Ten entries in two parts. Each entry carries a date and the name of whoever confirmed it.

| Part | Entry | Where the fact comes from | Who keeps it |
|---|---|---|---|
| Company copy | 1. Status: introduced on a date, application filed or not, where review stands | SourceX's correspondence with the company | The company |
| Company copy | 2. Records described: families, systems and years, as the company stated them | The company's own description | The company |
| Company copy | 3. Duties: holds, retention rules, customer or employee data limits | Counsel | The company |
| Company copy | 4. Decision waiting: continue, pause or stop, for the new decision-maker | The outgoing CEO, in plain words | The company |
| Company copy | 5. Contacts: who at SourceX the company deals with | The company | The company |
| Partner file | 6. Dated introduction evidence | The partner's own records | The partner, and SourceX on request |
| Partner file | 7. The signed Channel Partner Agreement and its version | The partner | The partner |
| Partner file | 8. The partner's correspondence with SourceX | The partner | The partner |
| Partner file | 9. The new decider's name and the date the company confirmed it | The company | The partner |
| Partner file | 10. Any economic interest the fund still holds, disclosed | The fund's own conflict policy | The partner |

Some things belong in neither part: board materials, the price or terms of the sale, the buyer's identity before it is public, diligence findings and any sample of the records. A packet that carries them has stopped being a handoff and become a leak.

The split matters because the two halves answer to different people. The company copy is the company's information about its own conversation, and the outgoing CEO decides whether and when it reaches the new owners. The partner file is evidence for attribution: section 2 of the program terms says credit is decided "from dated records, including written introduction evidence, existing applications and preexisting relationships." No side letter between old and new owners can move that credit, because SourceX decides it from those records.

## Transition events, preservation duties and the packet

| Event | Custody | Control | Packet action |
|---|---|---|---|
| Sale process begins, fund still on the board | Company systems | The company's CEO | Nothing changes; the fund keeps its partner file current |
| Data room opens | Company systems, plus diligence copies | The company's CEO | Diligence copies never enter the packet |
| Signing | Company systems | The company's CEO, within the agreement's covenants | The outgoing CEO decides, with counsel, whether entries 1 to 5 reach the buyer before closing |
| Closing | Company systems now owned by the buyer, or the purchased records in the buyer's hands | The acquirer's CEO | The company copy reaches the acquirer's CEO; the partner records entry 9 |
| Integration and any transition services | Records may stay on the seller's systems for a period, then move | The acquirer's CEO | The company updates entries 2 and 3 if records move or retire |
| Seller's retained copies destroyed or archived | Seller's copies gone or locked away | No change for the company | The partner file notes the date, if the company shares it |

Two duties can freeze records at any of these steps: a claim under the purchase agreement, and personal data obligations the buyer has taken on. Counsel decides what must be preserved before anyone revisits a licensing conversation. For a sale already under way when the referral was made, the milestone the referral had reached by closing matters too, and [what happens to a fund's referral when the company is sold](/guides/what-happens-to-a-fund-s-referral-when-the-company-is-sold) walks through each one.

## Hand off, wait or close the file

- **The acquirer's CEO wants to continue.** The company tells SourceX who now speaks for it, and the partner sends SourceX a dated note confirming entry 9.
- **The acquirer's CEO wants time.** Record the date and the reason, and do not chase. Nothing in section 2 pauses the 90-day attribution window while a deal closes.
- **The acquirer's CEO says no.** Close the partner file with the date, and nobody raises it again with the integration team.
- **Only the shareholders changed.** Update the partner file; the company's CEO carries on.
- **Nobody can name the decider yet.** Wait until the company does.

## Two handoffs worked through (Illustrative)

Illustrative. Both sales are invented, the companies are generic, and neither implies an outcome.

**A stock sale with a verified application on file.** A 240-person logistics software company, venture-backed, filed a verified application with SourceX in May 2026 after the fund's platform lead introduced it. In August it agreed to be bought by a larger software group. The founder-CEO prepared entries 1 to 5 and, on counsel's advice, shared them with the buyer only at closing in October. The acquirer's CEO paused the conversation for the first 60 days of integration and then asked SourceX to continue. The partner file held the dated introduction and the agreement. The company now sits inside the buyer's group; the program has no cap on rewards, and the USD 50,000 floor applies once, to this company's first qualifying transaction, with further qualifying transactions first agreed within the 12-month Repeat Window paying 15%.

**An asset sale where the records went with the assets.** A 120-person regional facilities business sold its operating assets, including its work order and customer service systems, to a new owner-operator, and kept its own tax records. The founder had told the fund she would hear more about SourceX, but no introduction had been submitted when she retired at closing. Entry 4 read: "decision waiting: whether to start a conversation at all." She passed the company copy to the buyer's CEO with the records handover, and the buyer's CEO chose to look at it after a first year of ownership. The fund's partner file recorded that date and closed; any later introduction would be a new one, starting its own 90-day window.

## Risks that could make the handoff go wrong

- **Credit cannot be arranged.** The terms decide credit from dated records, not from anything old and new owners agree. A packet that promises credit to anyone misstates the program.
- **Group history is an open question.** If the buyer, or a company it already owns, has dealt with SourceX before, nobody can say in advance what that means for the introduction of the business it just bought. The published terms say nothing about group history, and SourceX rules on it when it screens the introduction for duplicates.
- **Partner changes are open too.** The terms do not spell out what becomes of an introduction still in review if the person who submitted it leaves the program. Ask SourceX before that happens instead of assuming an answer.
- **Privacy commitments travel with the data.** The purposes and lawful basis the company had before the sale constrain the buyer afterward, and the ICO code makes checking them part of the buyer's diligence.
- **Deal confidentiality.** A careless packet can reveal a sale before it is announced. The company copy stays inside the company until its CEO decides otherwise.
- **Demand.** Whether a current SourceX program wants the company's records is decided in review, and a sale changes nothing about that.

**Methods note.** The change table and the packet apply SourceX's program terms (version 2026-10-22.2, since replaced by version 2026-11-04) and its who-qualifies page, 26 CFR 1.197-2 and the ICO's data sharing code, all checked on 2026-10-27. Entries were chosen to keep the company's information apart from the partner's attribution evidence. The two examples are Illustrative. Nothing here measures how often referrals survive a sale, and no such figures have been published. A fund can start measuring by logging each sale, the referral's status at signing and the acquirer CEO's answer.

## 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 sale is coming and a referral is open, [register as a partner](/register) if you have not, check the company's facts against [who qualifies](/who-qualifies) and read the [program terms](/terms), then build both halves of the packet before signing. Related cases are covered in [briefing a newly appointed CEO](/guides/how-to-brief-a-newly-appointed-ceo-about-an-existing-referral), [gradual ownership transitions](/guides/gradual-business-ownership-transition) and the [venture platform teams overview](/for/venture-platform-teams), with more in the [guides hub](/guides).

Handing a referral across a sale is partner work; anyone assessing SourceX as an investment can request its investor materials through the [SourceX investor overview](https://sourcex.si/investors).

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.

## Sources

- https://refer.sourcex.si/terms
- https://refer.sourcex.si/who-qualifies
- https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRcc67ec453a5e514/section-1.197-2
- https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-sharing/data-sharing-a-code-of-practice/due-diligence/
- https://sourcex.si/investors