Regulation S-P: can an advisor share client names for an introduction?

Only with care. Regulation S-P, the SEC's privacy rule for broker-dealers, registered investment advisers and funds, limits sharing nonpublic personal information about individual clients with nonaffiliated third parties. For a referral, get the business owner's consent first, let them direct the introduction, share business fit facts only, and ideally have them apply through your referral link.

The short answer for wealth advisors

Treat the fact that a business owner is your client, and anything you know from managing their money, as nonpublic personal information under Regulation S-P. Privacy rules of this kind make room for disclosures the client consents to or directs, so the clean path is an owner-directed introduction: you ask, the owner agrees in writing, and you pass on only the business fit facts the owner approved.

The cleanest version involves no sharing at all. The owner applies through your referral link, SourceX hears about the company from the company, and your credit is preserved.

What Regulation S-P covers

Regulation S-P is the SEC's privacy rule for broker-dealers, SEC-registered investment advisers and investment companies. In outline:

Whose information. Individuals who obtain financial products or services for personal, family or household purposes. The fact that someone is your customer is generally treated as nonpublic personal information in itself.
What it requires. Privacy notices, an opportunity to opt out before information is shared with nonaffiliated third parties outside listed exceptions, and written policies to safeguard customer records.
Where it comes from. It is the SEC's counterpart to the Gramm-Leach-Bliley Act privacy framework that the FTC applies to financial institutions within its jurisdiction; the FTC's Gramm-Leach-Bliley Act guidance describes the same pattern of notices and opt-out rights before sharing with certain nonaffiliated third parties.

The SEC adopted amendments to Regulation S-P in 2024, with compliance phased in across 2025 and 2026 depending on firm size. Read the SEC's current rule text, ask your chief compliance officer which date applies to your firm and read the updated policies before you introduce anyone.

Which details of an introduction are covered

Sort what you know before you say anything.

Detail	How Regulation S-P likely treats it	How to handle it
The owner's name and the fact they are your client	Generally nonpublic personal information	Share only with consent or at the owner's direction
Account values, net worth, liquidity or estate plans	Nonpublic personal information	Never share; none of it bears on fit
Exit timing or sale plans from planning meetings	Nonpublic and confidential	Never share
Company name, industry, headcount band, years operating, system types	Business information rather than consumer financial information, but learned through the relationship	Share only what the owner approves
The company's own records: email, CRM, finance, support	Not yours to share under any rule	Never; the company handles them with SourceX under a signed agreement

The owner-directed introduction, step by step

Raise it where the business is already on the table: an annual review, a liquidity discussion or an exit-planning meeting.
Disclose the possible reward and who pays it before you ask anything else.
Ask whether the owner wants to explore licensing and what, if anything, you may pass on.
Get the answer in writing and file it the way your firm's books-and-records procedures require.
Send your referral link so the company applies at sourcex.si/apply itself, with your referral code attached and no client data passing through you.
If the owner asks you to submit on their behalf, use the referral form with only the approved fit facts and the sponsor's business contact details.
Step back. SourceX qualifies the company on size, history, data breadth and rights, and the owner deals with SourceX directly from there.

A script for the planning meeting:

How it applies in common advisor situations

Situation	What to check	Typical outcome to confirm
A solo or small RIA introduces a long-time client	Your privacy notice, written policies and conflict disclosures	Owner-directed introduction with written consent
A dual registrant whose broker-dealer supervises outside activities	Whether the referral partnership must be reported or approved	Tell the firm before registering; see the note below
An advisor at a bank or broker-dealer branch	Firm approval and employer policy on outside compensation	The firm's policy decides; ask before acting
The business is held through a trust or holding company	Who has authority to agree for the company	Get consent from the authorized sponsor, not only your individual client
A study group or referral network asks members to swap client names	Whether sharing names breaches privacy duties	Do not share client names with the group

For dual registrants, FINRA has reported that the SEC approved new FINRA Rule 3290 on 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. CFP professionals also carry the duties set out in the CFP Board's conflict disclosure standards.

Questions for your chief compliance officer

Does our privacy notice or policy restrict introductions to third parties even when the client consents?
What form of client consent does the firm require, and where must it be kept?
Is a referral partnership an outside activity that needs pre-approval or reporting?
Must the reward appear in our conflict disclosures, or be credited to the client?
Should the firm rather than the individual advisor be the registered partner?

How the reward works for advisors

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, and rewards become payable only after the buyer pays and SourceX receives its fee. Nothing is payable for a lead, a meeting or a signed agreement on its own, and no reward is guaranteed. The reward is a share of SourceX's fee, so it never reduces what the owner's company receives. If you would rather credit or decline it, see how advisors weigh passing a referral fee through to clients.

Record the consent and your disclosure with how to document client consent before an introduction. Lawyers working with the same owner face a parallel question under their own rules, covered in the lawyer's version of this question under Rule 1.6. The program terms cover attribution.

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

Next step

You can test a client's business against the baseline without naming anyone: the company fit checker gives an early, non-binding indication without asking for contact details. Once compliance signs off, register as a partner and send the owner your referral link.

Step 1Share your linkSend your personal link to a company you know.
Step 2Company appliesThe company applies itself at /apply.
Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Does Regulation S-P protect information about a client's business?

Its focus is information about individuals who obtain financial services for personal, family or household purposes. Facts about a company are business information, but tying them to your client relationship usually reveals nonpublic personal information about the owner. In practice, treat both as confidential and share either only with the owner's agreement.

Is a client's verbal permission enough before an introduction?

Your firm's policies decide the form, and your compliance team will likely want it in writing. A short email asking the owner to confirm what you may share, followed by a one-word reply, creates a record that fits normal books-and-records practice and protects both you and the client if anyone asks later how the introduction happened.

Did the 2024 amendments to Regulation S-P change how referrals work?

Do not assume they created a referral exception; check the SEC's current rule text and ask your compliance team. Their practical effect, in any case, is closer attention to where client information goes, which makes an owner-directed introduction with written consent and minimal sharing the sensible default.

Can I describe a client's company to SourceX without naming it?

Be careful: a detailed description of a business can identify it as surely as a name, especially in a small industry or town. If you only want a sense of fit, run the company fit checker yourself, which needs no contact details. Anything beyond that should wait for the owner's consent.

Do state privacy laws add anything for advisors?

They can. Some states have their own financial privacy or consumer privacy rules that sit alongside federal requirements, and your firm's policies may already reflect them. Ask your compliance team whether any state rule affects an introduction where you or the client are located before you share anything.

Free resources

Due diligence checklist generator — A tailored document request list by deal type.
Cash flow calculator — A 12-month cash forecast with shortfalls highlighted.
Referral earnings calculator — Hypothetical partner earnings with the per-company cap.
All free tools · MCP resource center

By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09

Know a US company with valuable proprietary data?

Become a referral partner from anywhere we support, get your link and introduce an owner or authorized decision-maker.

Refer a company →

I own a business

Explore licensing your company's data to AI developers worldwide. Start a short assessment; no uploads needed.

Start an assessment