Can You Self-Invest in a Morningstar International SIPP?

Disclosed services and delivered services have to match

There is a further layer to this for SEC-registered advisers specifically. A registered firm must describe its advisory business in its Form ADV, including the types of advisory services it offers, how those services are delivered and the fees it charges for them. That disclosure has to be accurate and not misleading, and the firm is expected to deliver services consistent with what it has disclosed and with the client advisory agreement.

This is where a self-invest arrangement can create a problem that goes beyond any single client file. If the Form ADV of a firm describes its services as advised or discretionary portfolio management, and its fee schedule is built around that, then providing what is in substance a self-directed, no-advice service while still charging an advisory fee is materially different from what has been disclosed. Where the disclosed model is advice and the delivered reality is self-direction, that gap is the kind of issue that attracts regulatory attention, quite apart from the fiduciary and suitability concerns already described.

For a client, this is worth understanding because it reframes the question. It is not only whether you are receiving good value, but whether the service you are actually receiving matches the service the firm has told its regulator, and told you, that it provides.

Why US Residents and Expats Keep Getting Pushed Off UK Platforms

Many people searching for a way to self-invest with Morningstar arrive at that search having just been told to leave somewhere else. Interactive Investor has told US-resident clients to transfer their SIPP, ISA and general investment accounts out, with cut-off dates communicated individually and reported as falling in January 2026. We covered it in our guide to the Interactive Investor closures and, for pensions specifically, here. Vanguard UK places restrictions on accounts for non-UK residents generally, but its published position on US persons is more specific: it does not offer its services to US persons, and a client who moves to the US will need to close the account or transfer to another provider, which we set out in our Vanguard guide. Bestinvest has been closing US-resident accounts, covered here, and Hargreaves Lansdown, AJ Bell and most other major UK retail platforms carry similar restrictions on US-resident clients.

The reason is widely understood, and it is regulatory rather than commercial pique. US registration requirements can be triggered where a firm advises or deals for a person resident in the United States, and the exemptions available to a purely non-US firm are narrow. A UK-only platform that is not registered in the US, and does not have an appropriately registered adviser in the chain, is exposed if it services US persons directly. Faced with that, most UK platforms simply decline to serve US persons at all. That is why Vanguard singles out US persons rather than applying the milder restriction it uses for other overseas clients, and why Interactive Investor is exiting the US-resident market.

This is where the self-investment question becomes more than a matter of convenience. An arrangement that lets a US person self-direct investments through a platform, with no properly registered US adviser or broker-dealer in the structure, is operating in exactly the territory those registration requirements are designed to capture. Running an adviser-led platform as though it were an execution-only service does not sidestep that exposure. If anything it risks recreating it, potentially for the platform and the adviser firm as well as the client, which is one reason the distinction is not merely academic.

The point for a US person is straightforward. The presence of a genuinely SEC-authorized adviser representative in the structure is part of what keeps a US-connected pension arrangement on the right side of these rules. It is not a box-ticking formality, and it is not something that can be satisfied by an adviser whose name is attached to the account but who is not actually providing an ongoing, regulated service.

The Risk of an Advised-in-Name-Only Structure

Where a SIPP is opened on an adviser-led platform but is, in substance, operated as though it were self-directed, three separate obligations are put at risk at once: the terms of business between the platform and the adviser firm, the terms of business between the adviser and the client, and the fiduciary duty of the adviser under SEC rules. Any one of these being unmet is a problem. All three being unmet at the same time, on the same account, is a structural issue rather than an isolated oversight.

For the client, the practical risk is straightforward. An advisory fee is being paid for a service that is not, in substance, being delivered, and the pension holdings may drift out of suitability with nobody actively monitoring for it. If a dispute or a regulatory question ever arises, the absence of a documented, ongoing review trail is difficult to remedy after the fact.