Do you have to disclose a referral fee to your client before you introduce them?

The short answer: it depends on your profession, and early disclosure is the safe default

Whether a rule forces you to disclose a referral fee depends on who you are. CPAs, lawyers, registered representatives and court-appointed fiduciaries each answer to their own rulebook; business coaches, consultants and peer-group chairs mostly answer to their client contracts and to plain fairness rather than one professional code. In every case, the cleanest moment to disclose is before you ask the owner whether you may make the introduction.

For a SourceX introduction the conversation is easy to have. The partner reward is a share of SourceX's own fee and is never deducted from what the company receives, so telling the owner costs them nothing. It still matters: the conflict that disclosure rules target is your incentive to recommend, not the client's price.

What do the primary rules actually say?

These are the rules most partners will meet. Treat each one as a starting point, because state versions and firm policies can be stricter.

CPAs: the AICPA commissions and referral fees rule

Under ET 1.520 of the AICPA Code of Professional Conduct, a member in public practice may not accept a commission for recommending a product or service to a client when the member or the firm also performs an audit, review, certain compilations or an examination of prospective financial information for that client. Where a commission or referral fee is permitted, it must be disclosed to the client. State boards can go further than the AICPA Code, as the New Jersey Society of CPAs points out for its own state, so read your board's rule as well.

Lawyers: financial interests connected to a client matter

The ABA Model Rules of Professional Conduct are a template that each state adopts in its own form. Where a lawyer would hold a financial interest connected to a client matter, Model Rule 1.8(a) is the usual reference point: it permits a business transaction with a client only if the terms are fair and reasonable and disclosed in writing, the client is advised in writing to seek independent counsel, and the client gives informed consent in a signed writing. Whether that rule reaches a fee paid by a third party for an introduction is a question for your state bar's ethics guidance.

Registered representatives: your firm hears first

For anyone registered with a FINRA member firm, the first disclosure runs to the firm, not the client. FINRA reported that the SEC approved new Rule 3290 (Outside Activities) on September 15, 2026, replacing Rules 3270 and 3280, with the effective date to be announced in a Regulatory Notice. Until then, Rules 3270 and 3280 apply. Client disclosure then follows your firm's written procedures.

Anyone who recommends SourceX in public

If you post about SourceX on a website, newsletter or social profile while earning a referral share, the FTC's Endorsement Guides FAQ says the connection should be disclosed clearly and close to the recommendation, on each platform. No wording is mandated, but the FAQ treats a plain statement that you are paid as clearer than a bare label such as affiliate link.

Profession by profession: rule or good practice?

When should you disclose: before or after the introduction?

Before. Disclose at the point the owner decides whether to let you introduce them, not after a license closes. A late disclosure reads as concealment even when the reward never touched the client's price.

1. Check your own rule and firm policy, and get written approval where your firm requires it.
2. Tell the owner that SourceX would pay you a share of its fee if a license closes, that payment comes only after the buyer pays and SourceX receives its fee, and that nothing comes out of the company's proceeds.
3. Ask whether they want the introduction and record the answer; the client consent form for a business introduction gives you a ready template.
4. Make the introduction with your referral link or the referral form, as described in how SourceX referrals work.
5. Keep a dated note of the disclosure and the consent in the client file.

A disclosure line you can use

Once the owner says yes, the introduction email builder can draft the follow-up note.

What the SourceX structure changes, and what it does not

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; an introduction, meeting or signed agreement alone does not trigger payment, and no reward is guaranteed.

Because the reward is paid out of SourceX's fee, it never reduces the company's proceeds, which takes the cost question out of the disclosure conversation. It does not remove your duty to disclose, your independence analysis or your firm's say over who gets paid; the page on whether a referral fee should be paid to you or your firm covers that choice. If your role grows into negotiating terms, the analysis changes again, and the finder's fee vs referral vs broker comparison explains where that line usually sits. M&A advisors who already bill the same client a success fee should also read success fee vs referral fee, because the two arrangements are disclosed separately.

Questions to ask your compliance team or counsel

• Does my rule treat this payment as a commission, a referral fee or something else?
• Does the client relationship (attest work, legal representation, an advisory account, an estate) change the answer?
• Must the disclosure be written, and must it state an amount or only the method of calculation?
• Who should be the payee: me, my firm, or no one?
• Is written notice enough, or do I need the client's signed consent?

This is general information, not legal, tax or financial advice. Confirm with your own counsel, compliance team or professional body before acting.

Next step

Settle which rule applies to you, then disclose and ask. When you are ready, register as a partner to get your referral link and make the introduction.