US Securities + Commodities (Forex) Regulatory Assessment — Automated Trading Software Platform

OVERVIEW I'm the founder of a subscription software platform that runs proprietary algorithmic strategies and executes trades in each subscriber's own brokerage account. I need a US-licensed attorney with both securities and commodities/forex regulatory experience to assess our model and tell us how to structure and launch it compliantly. Fixed-scope regulatory assessment first; contract drafting is a likely phase 2. HOW THE PLATFORM WORKS (these details drive the analysis) Subscribers pay a flat monthly subscription to license access to our software. Our proprietary strategies generate signals on our server; subscribers never see or control the signal logic. Subscribers connect their own brokerage accounts via API — we never hold, touch, or custody their funds. The software auto-executes trades into the subscriber's own account once they arm a strategy, but the subscriber can pause, override, and set their own risk parameters (position size, stop loss, take profit). We trade both US-listed options (via Alpaca) and forex (via MetaTrader 5) — spanning SEC/securities and CFTC/forex. Distribution via Whop; one device-locked license key per subscriber. Subscribers: US and international. Stage: pre-launch, building our legal foundation before going live. QUESTIONS I NEED ANSWERED Does auto-executing our strategies into subscribers' own accounts for a subscription fee make us an investment adviser under the Advisers Act/SEC — and/or a commodity trading advisor under CFTC/NFA for the forex side? What registrations or exemptions apply (including whether any publisher's/bona-fide-publication exemption survives given the auto-execution + override model)? Forex specifically: what CFTC/NFA obligations (CTA registration, retail forex rules) attach to sending automated forex trades to subscribers? Revenue structures: we launch on a flat monthly subscription, but which fee models let us maximize earnings without triggering adviser/manager registration — flat subscription, platform/maintenance fees, tiered pricing, and future performance-based fees? For each: what's allowed, and what would it require? State registration: with US subscribers across multiple states, what state-level adviser/CTA registration or exemptions apply? International subscribers: at a high level, which jurisdictions should we gate or avoid at launch, and what's the safest footprint to start with? What disclosures and disclaimers must appear in our Terms and marketing to protect the company (no investment advice, user responsibility, risk)? How have comparable automated/copy-trading/signal SaaS platforms structured this legally? PRIMARY DELIVERABLE (this fixed-fee engagement) A written regulatory-risk assessment / legal opinion memo: whether and how we can legally operate and charge as designed; what registrations or exemptions apply (SEC + CFTC + state); which fee structures are viable; and a clear "here's how to structure it to launch compliantly" recommendation. Terms of Service · User/Subscriber Agreement · Risk Disclaimer · performance-fee structuring note. REQUIREMENTS US-licensed attorney with both securities (Investment Advisers Act) and commodities/forex (CFTC/NFA) regulatory experience. Florida licensure a plus, not required. Experience with fintech / automated-trading / copy-trading platforms strongly preferred. Fixed fee; no hourly. TO APPLY, INCLUDE Your bar admission(s) and state(s). Your securities and commodities/forex regulatory experience, with examples. Your proposed fixed fee for the regulatory assessment and contract drafting. BUDGET: $800 fixed. Open to a higher-value scope for the right expert.