leasing my ea vs running a managed account

For some time i've entertained the idea of setting up a managed account with a US broker, but the exorbitant NFA fees have kept me from doing it, even though I've already passed the various series exams. it may not be much of a fee for a hedge fund, but it's prohibitive for a one-man operation just starting out. i'm now considering just drafting individual contracts directly with clients for development and operation of a forex EA that places trades on their accounts from my server. i could charge them whatever we agree on in the contract for the EA lease, and it could be tied to any random quantity like the ocean tides, daily weather, or the monthly profit in their account.

My clients would be essentially hiring me or my LLC as a contractor to be their programmer and IT guy that runs the servers, and I wouldn't be manually placing trades in their account or offering financial advise. They will just happen to be paying me a variable fee that could correlate with their account's performance. Is there any way the various regulators can stick their noses in these contracts to 'protect' us from ourselves? Is there a better way to do this without sending clients to some shady foreign bank? i'm not looking to scam anyone. i'm trying to do right by my clients within the law and using the most affordable legal arrangement available.

Why don't you try becoming a signal provider? There's no licensing involved.