Holding company subsidiary review template with a records and rights check

When to use this subsidiary review template

Use this template once a year for every operating subsidiary, timed to the annual plan sign-off, when the subsidiary president and the holdco reviewer already have the year's numbers on the table. Sections A to E cover the review a decentralized holding company runs anyway. Section F adds five metadata-only questions (systems, years, rights, sponsor and red flags) that screen each subsidiary for a possible data license.

Monthly packages show revenue, margin and cash, not the decade of service tickets, quotes, job files and engineering change records sitting in systems nobody has opened since the last migration. Records like these can be licensed to AI labs and data buyers that train and evaluate AI agents on real business workflows, for a one-time payment, while the subsidiary keeps ownership.

A group that buys to hold keeps every year of a subsidiary's history inside the group, which is the depth buyers look for. The template assumes each subsidiary runs its own systems; if your group moves acquisitions onto shared platforms, the differences in holding company vs roll-up apply and section F must cover the shared systems too.

What does the full annual subsidiary review cover?

Six sections, each with a named reviewer. Keep A to E in whatever form your group already uses.

Read E and F together: a data license is a contract outside the normal course of business, so check whether your matrix reserves it for the holdco; holdco decision rights: who signs a subsidiary's data license? sets out the usual options.

Section F: the records and rights check

Answer with system names, year counts and yes, no or not yet reviewed. Nobody exports, attaches, summarizes or describes the content of any record, at this stage or any later one.

F3 needs the most care. Under US copyright law, material employees prepare within the scope of their jobs is generally a work made for hire owned by the employer, while material from contractors may not be unless rights were assigned in writing; the Copyright Office explains the test in Circular 30 on works made for hire. Ownership is only half the question, because contracts and privacy promises can still limit use. FTC staff warned in February 2024 that adopting more permissive practices, such as using consumers' data for AI training, through a surreptitious or retroactive change to terms of service or a privacy policy could be unfair or deceptive (staff guidance, not a rule). A no on F3 is not fixed by quietly rewriting the policy. For subsidiaries the group acquired, also check what the purchase agreement transferred; can an acquired company license its pre-acquisition records? covers the common situations.

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

How to read the answers: pass, fix, hold or park

Apply one rule: a single hard red flag parks the subsidiary, while a gap that can be closed keeps it on the list.

Before introducing a pass, compare it with the published who qualifies baseline: US companies with 50+ full-time employees at peak (contractors excluded), several years of documented operations, rights to license the data and an authorized sponsor. The company fit checker gives a preliminary, non-binding read with no contact details required.

The request note and review pack line

Send the first three paragraphs with the review pack; use the last line to report the result.

How to personalize the template

Follow-up timing

If a sponsor wants to proceed, the holdco never touches the data:

1. The holdco partner sends the sponsor a referral link to the company application, or submits the subsidiary through the referral form.
2. SourceX qualifies the subsidiary with the sponsor, and the subsidiary completes a data inventory of systems, years and exportable records.
3. Price and terms are agreed; nothing is binding until the subsidiary signs.
4. AI labs and data buyers review the opportunity; after an executed agreement and the subsidiary's authorization, data is delivered under the agreed redaction rules and the subsidiary receives a one-time payment.

What never goes in the review pack

• Exports, samples, screenshots or excerpts from any system
• Customer, patient or employee names connected to records
• Estimates of what a license might pay; price is agreed between SourceX and the subsidiary, and no figure exists before then
• Typed reward figures or promises about a referral reward
• Any statement that a subsidiary qualifies before SourceX has reviewed it

How referral rewards work when the holdco introduces a subsidiary

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. Rewards become payable only after the buyer pays and SourceX receives its fee, and no reward is guaranteed. The reward is a share of SourceX's fee and is never deducted from what the subsidiary receives.

Because the holdco owns the business it introduces, read referral rewards when you also own equity in the referred company and the program terms before registering, and agree internally whether the holdco or a named individual is the referrer.

Next step

Add section F to this year's review pack and send the request note six weeks out. When a subsidiary passes, register as a partner and send the sponsor your referral link, or have the sponsor apply directly at sourcex.si/apply.