Accountants, bookkeepers, insurance agents and business consultants see their clients' finances up close, often before a bank does. When a client needs capital, the advisor is frequently the first person asked. Turning that moment into a structured funding service can help clients, but it also brings rules most advisors have not dealt with before.
Why advisors are well placed to help with funding
Business owners pick lenders mainly through relationships and referrals, and advisors hold both. In the Federal Reserve Banks' 2026 Report on Employer Firms, an existing relationship was the most cited reason for choosing a lender among applicants at large banks (62%) and small banks (61%). Between 16% and 20% of applicants at banks and online lenders cited a recommendation or referral (Federal Reserve Banks: 2026 Report on Employer Firms).
The same report shows why preparation matters. Among applicants who did not get all the financing they sought, 46% said lender requirements were too strict and 37% said they already had too much debt. An advisor who knows a client's financials can steer them toward lenders whose criteria they meet, or tell them to wait.
Two ways to add a funding service
You can refer clients to a lender, broker or marketplace, or you can broker deals yourself. The difference matters for licensing.
| Refer out | Broker yourself | |
|---|---|---|
| What you do | Introduce the client; a partner handles matching and closing | Match, package and support the deal through closing |
| Typical pay | A referral fee from the partner, if any | Compensation from the lender or funder |
| Licensing exposure | Can still count as broker activity in some states if you are paid | Registration or licensing likely in several states |
| Time required | Low | High |
Referring out is not automatically outside the rules. California's AB 2116, signed in September 2026, counts referring a business to a provider for compensation as commercial financing broker activity, and requires a license for covered deals of $500,000 or less from July 1, 2028, according to Morrison Foerster's analysis. Virginia defines a sales-based financing broker as anyone who, "for compensation or the expectation of compensation, obtains or offers to obtain" that financing for a business, and requires brokers to register (Va. Code Title 6.2, Chapter 22.1). Texas requires providers and brokers of commercial sales-based financing to register with the Office of Consumer Credit Commissioner by December 31, 2026 (Texas OCCC rule adoption). Our guide on becoming a business loan broker covers these state rules in detail.
If you refer without taking any payment, most of these definitions are not triggered, because they turn on compensation. Confirm that with a lawyer for each state where your clients are located.
Rules specific to accountants and other professionals
CPA ethics rules on commissions and referral fees
State boards of accountancy restrict commissions for CPAs who also provide audit, review, compilation or tax services. Minnesota's rule is a clear example. A licensee "shall not for a commission recommend or refer to a client any product or service" while performing for that client an audit or review of financial statements, certain compilations, an examination of prospective financial information, or the preparation of a tax return or refund claim. Where a commission is permitted, the licensee must disclose it. A licensee who accepts a referral fee for recommending another licensee's service, or pays one to get a client, must disclose that to the client (Minnesota Rules 1105.7800).
Other states have their own versions, and the tax return limit in Minnesota's rule is stricter than many firms expect. A CPA firm that prepares a client's tax return should check its state board's rule before accepting any lender or broker payment for that client.
SBA loans: accountants are "Agents"
If a client's financing is an SBA 7(a) or 504 loan, an accountant who is paid in connection with it is an Agent under federal rules. SBA's regulations define an Agent as "an authorized representative, including an attorney, accountant, consultant, packager" and others acting for an applicant or lender. Any applicant, agent or packager must execute a compensation agreement and provide it to SBA, which in practice is SBA Form 159, the Fee Disclosure and Compensation Agreement. Agents generally may not be paid by both the applicant and the lender for the same work, and SBA can require unreasonable fees to be refunded (eCFR: 13 CFR Part 103).
Advance fees
Florida's loan broker law bars a loan broker from collecting an advance fee, meaning anything collected before the loan closes (Fla. Stat. §§ 687.14 and 687.141). Charging clients only when financing closes, or not at all, avoids that problem and is easier to explain.
A four-week setup plan
Spend the first two weeks on compliance and partners, and the last two on clients. This order avoids having to unwind arrangements later.
Week 1: Decide the model and check the rules
- Choose between referring out and brokering yourself.
- List the states where your clients are located and check each one's broker registration or licensing rules on the regulator's own site.
- If you are a CPA, read your state board's rule on commissions and referral fees.
Week 2: Choose partners
- Pick a small number of lenders, brokers or a marketplace that cover the products your clients most often need: lines of credit, term loans, equipment financing, SBA loans.
- Ask each partner how it is paid, whether it is registered or licensed where your clients are, how many lenders see each application, and whether offers show an APR. Our research on how lending marketplaces make money explains why those answers matter.
- Get any referral fee arrangement in writing.
Week 3: Build the client process
- Write a one-page disclosure that tells clients what you are paid, by whom, and that they are free to apply elsewhere.
- Create a short intake: time in business, monthly revenue, credit range, existing debt payments and use of funds.
- Prepare a document checklist. Our list of business loan documents is a starting point.
Week 4: Offer it to existing clients
- Tell clients the service exists, in your normal newsletter or meeting cadence.
- Start with clients who have a clear, near-term need rather than pitching everyone.
- Review each offer with the client in APR and total cost terms before they sign.
Common mistakes
- Taking a fee before checking licensing. In California, Virginia and Texas, the fee itself can make you a broker.
- Not disclosing compensation. Minnesota's CPA rule requires it, Virginia requires providers to disclose broker pay in the offer, and clients will see it anyway.
- Treating every product as the same. A six-month advance repaid daily and a five-year term loan can have the same dollar cost and very different APRs.
- Forgetting the SBA paperwork. Paid involvement in an SBA loan means a compensation agreement on Form 159.
Loanistry is owned by Trulli, which runs a lending platform for brokers, agencies and software companies: trulli.ai.
Sources
- Federal Reserve Banks: 2026 Report on Employer Firms, checked November 2026
- Morrison Foerster: California Expands the California Financing Law to Include Small Business Commercial Financing, checked November 2026
- Virginia Code: Title 6.2, Chapter 22.1, Sales-Based Financing, checked November 2026
- Texas OCCC: Commercial sales-based financing rules adoption, checked November 2026
- Minnesota Revisor of Statutes: Minnesota Rules 1105.7800, Code of Professional Conduct, checked November 2026
- eCFR: 13 CFR Part 103, Standards for Conducting Business with SBA, checked November 2026
- SBA: SBA Form 159, Fee Disclosure and Compensation Agreement, checked November 2026
- Florida Senate: Florida Statutes Chapter 687 (2026), checked November 2026