For some time I've been toying with the idea of setting up a forex managed account service, and I've gone ahead and passed the series 3, series 34, and series 65 exams. I suppose the next steps would be to register with the nfa as a cpo and a cta, but the fees to do this are a little ridiculous for a little guy just starting out.
Is it possible to instead structure a contract with my clients in such a way they're paying me to maintain the ea, essentially as a lease agreement? Technically i wouldn't be making any trades in their accounts, just my ea will be making the trades, and they're hiring me to set it up, configure it and maintain the ea, not to place trades.
We could make the lease fee variable, and it may just so happen to wind up being somewhat correlated with the performance of their accounts.
Is this legal or is there any way the government can still find a way to screw me and my clients?