NFA rules on this stuff.
You have to file under NFA Rule 2-8 (E). You should use part a) according to your description of what you wish to do. If these folk are relatives, you still have to file and part d) applies.
The rule is time governed (12 month cycle) and limited to how many persons you can deal with (up to 15). It is not broad, meaning your POA's in equities do not count.
Filing is manditory and updating your filing is manditory.
By filing, you exclude yourself from a lot of other possible activities.
There is a key disclosure issue as well. Once you disclose, CFTA has the record or access to it out of your control to prevent it from making the rounds.
Your employer (no matter who) becomes part of the record as well.
You have to file under NFA Rule 2-8 (E). You should use part a) according to your description of what you wish to do. If these folk are relatives, you still have to file and part d) applies.
The rule is time governed (12 month cycle) and limited to how many persons you can deal with (up to 15). It is not broad, meaning your POA's in equities do not count.
Filing is manditory and updating your filing is manditory.
By filing, you exclude yourself from a lot of other possible activities.
There is a key disclosure issue as well. Once you disclose, CFTA has the record or access to it out of your control to prevent it from making the rounds.
Your employer (no matter who) becomes part of the record as well.