Can a CFO advisory firm sell its data to AI?

Outsourced CFO and advisory firms hold forecasts, board materials and deal data. What is client information and what might be licensable.

Last updated 4 sources cited1 min read

Short answer: Mostly not the client work. Forecasts, board decks, fundraising and deal material are client confidential information and often covered by NDAs. A firm could consider its own methods, templates and operations. Whether Mode's 15+ accounting rule applies depends on how Mode classifies your firm.

On this page
  1. What advisory files hold
  2. Rules that can apply
  3. What could be in scope
  4. Size
  5. Before you call a buyer
  6. Frequently asked questions
  7. Sources

What advisory files hold

  • Forecasts, budgets and cash models.
  • Board and investor materials.
  • Fundraising and M&A data, sometimes material nonpublic information.
  • Client banking and payroll access.

Rules that can apply

CPA firms answer to their state board's confidentiality rule; Texas requires written client permission for voluntary disclosure (22 Tex. Admin. Code § 501.75). If your firm is also a registered investment adviser, Regulation S-P limits disclosing customers' nonpublic personal information to nonaffiliated third parties (Reg S-P).

What could be in scope

  • Firm-authored model templates with no client numbers.
  • Engagement playbooks and onboarding checklists.
  • Internal training and knowledge-base content.

Size

Mode lists minimum team sizes of 10+ employees for legal, 15+ for accounting, medical and finance, and 50+ for all other businesses, for companies based in the US, Canada, the UK or Australia with several years of records they own (Mode).

Industry (U.S. firms, 2022)All firms15+ staff30+ staff50+ staff
Accounting, tax prep, bookkeeping & payroll (NAICS 5412)120,0858,0673,8082,368
Management consulting services (NAICS 54161)170,37310,2575,8313,945

Source: U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizes. Firms (enterprises) by paid employees; contractors are not counted. Each column sums the Census size classes at or above that size.

Before you call a buyer

This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.

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Frequently asked questions

Is a non-CPA advisory firm 'accounting' for Mode?

Ask Mode. If it's treated as consulting, the 50+ rule applies.

Can we license anonymized forecasts?

Client numbers are client information even without names. Keep them out unless counsel approves.

Sources

  1. 22 Tex. Admin. Code § 501.75, Confidential Client Communications (Cornell LII)law.cornell.edu
  2. 17 CFR Part 248, Subpart A (Regulation S-P) (Cornell LII)law.cornell.edu
  3. Mode / BizBuyData referral pagebizbuydata.com
  4. U.S. Census Bureau, Statistics of U.S. Businesses 2022, detailed employment sizeswww2.census.gov

Referral-fee disclosure: we may be paid by a program if your company signs with it after using this site. General information only, not legal advice.

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