Fees
Choosing a low-cost UK investment manager for a Stocks & Shares ISA comes down to seven questions: is the firm directly authorised by the FCA, is the total annual cost shown as a single figure, is the underlying investment approach evidence-based and explainable, are the principals co-invested on the same terms, are there any tie-in costs to leave, who actually holds the money, and is the minimum realistic for your situation. This page walks through each in order so you can compare any UK firm — including SCM Direct — on a like-for-like basis.
There is no perfect manager. There is the right manager for what you want, evaluated against criteria that matter. The criteria below are written so that the same questions apply whether the firm is a discretionary manager like SCM Direct, a robo-advisor like Nutmeg or Wealthify, or a DIY platform like Vanguard Investor or AJ Bell.
Before the seven questions, decide which product you are actually shopping for.
A DIY ISA platform is a fund supermarket. You choose what to hold (funds, ETFs, shares), when to buy and sell, and when to rebalance. Vanguard Investor, AJ Bell Youinvest, Hargreaves Lansdown, Interactive Investor and Fidelity Personal Investing are DIY platforms.
A discretionary ISA manager makes the investment decisions for you within a risk profile you select. SCM Direct, Killik & Co, Brewin Dolphin (now part of RBC), and Rathbones are examples of discretionary managers. So is Nutmeg, which is a discretionary robo-advisor.
Both can be low-cost. They are different products, and the right answer for you depends on whether you want to make the investment decisions yourself or have a regulated firm make them for you. The rest of this page applies to either.
Every legitimate UK investment manager handling client money must be authorised by the Financial Conduct Authority. The firm’s reference number — usually called the FCA FRN — should appear on its website, often in the footer. Verify it on the FCA Register at register.fca.org.uk. The Register shows which permissions the firm holds (discretionary investment management is the relevant one for a managed ISA), who is on the board, and any past enforcement actions.
A few things to check on the FCA Register page: – The firm has the permission you expect (managing investments — discretionary) – The address matches the address on the firm’s website – There are no recent supervisory notices or enforcement actions
If the firm is an Appointed Representative of another authorised firm rather than directly authorised, that is not automatically a problem — but it is worth understanding why.
SCM Direct’s FCA FRN is 497525. SCM Direct is a trading name of SCM Private LLP.
This is the most powerful test of whether a firm is genuinely fee transparent. The total cost of ownership of a UK Stocks & Shares ISA typically includes:
If you have to add these up yourself from different fee schedules, the firm is not being fully transparent — and you are likely paying more than the headline figure suggests.
The acid test: ask the firm to send you the total annual cost on a £50,000 ISA portfolio, in pounds and as a percentage, with every component included. A transparent firm will reply within 24-48 hours with a single number. A non-transparent firm will provide a fee schedule, and you will have to calculate the fee yourself.
At SCM Direct, the headline 0.85% is the all-in figure. It includes management, custody, all underlying ETF OCFs, trading and transaction costs – ALL COST & CHARGES. There is no separate platform fee, no per-trade dealing fee, no initial charge, no exit penalty, and no performance fee.
The strongest UK investment managers can explain — without using jargon — why their portfolios are constructed as they are, and they can point to public evidence supporting their approach.
Three signs the approach is evidence-based:
SCM Direct uses physically-replicating ETFs from established providers, weighted across eight risk-adjusted portfolios. The construction is documented on each portfolio’s page, and the SCM investment team rebalances these portfolios to take advantage of opportunities to grow your money.
The strongest alignment between an investment firm and its clients is the principal’s own money sitting in the same portfolios as clients, on the same terms, with the same fees, with no preferential access. This is not a regulatory requirement and is rarely advertised, which means asking directly is the only way to know.
A useful question to ask a firm during evaluation: “Do you and your senior investment team invest yourselves in the same portfolios as clients, on the same terms?”
At SCM Direct, Alan and Gina Miller co-invest their own and their family’s money in the portfolios on the same terms as clients. This is published explicitly on the firm’s About page.
A low-cost manager should not become an expensive one when you want to leave. Three terms and conditions to check before signing:
If the firm imposes meaningful exit costs, the relationship is asymmetric: the firm has every incentive to keep your money even when service is poor.
SCM Direct does not charge exit penalties or transfer-out fees. Notice is one month.
UK investment managers typically use a separate custodian to hold client assets — a standard regulatory requirement. The custodian segregates client money from the firm’s own balance sheet, so if the firm fails, your assets are not at risk in the firm’s insolvency.
Two things to verify: – The custodian is named on the firm’s website (not buried) – The custodian is independently FCA-authorised and has its own FRN you can check on the Register
At SCM Direct, custody is held by Hubwise Securities Ltd (FCA FRN 6071374). Assets are held in segregated client accounts.
UK discretionary investment management has historically been a high-minimum product — £100,000, £250,000, or even £500,000 was the typical minimum at traditional firms. The shift over the past decade has been toward much lower minimums (often £10,000 or less) for ETF-based portfolios.
SCM Direct’s minimum is £10,000 for all products and portfolios, save the Junior ISA, which is £9,000. The maximum is the annual ISA allowance (£20,000 for the 2026/2027 tax year) inside the ISA wrapper; uncapped outside.
This is not a comparison table — it is a self-assessment against the framework above. Apply the same seven questions to any other UK manager you are considering. A firm that scores well on six of seven is likely a good fit; a firm that scores poorly on more than two is worth a second look.
Yes — FRN 497525
Yes — 0.85% covers everything. No hidden charges.
Yes — physically-replicating ETFs, eight documented portfolios
Yes — Alan and Gina Miller
None — no exit fee, one-month notice
Yes — Hubwise Securities Ltd, FRN 6071374
£10,000
In addition to the seven questions, three patterns should give an investor pause to rethink:
For a DIY platform, all-in costs (platform + fund OCFs + dealing) typically range from 0.30% to 0.80%, depending on what you hold. For a discretionary managed ISA – managed by an expert team – all-in costs typically range from 0.85% to 2.0%. SCM Direct’s 0.85% is at the lower end of the discretionary range.
Robo-advisors like Nutmeg (now JPMorgan) and Wealthify are discretionary managers that use software-driven portfolio construction. Apply the same seven questions to them — FCA-authorised, all-in fee, evidence-based, alignment, exit terms, custodian, minimum. The decision then comes down to whether you prefer a software-driven approach or a human-led investment team.
Not exactly. Passive describes the investment approach (tracking an index rather than picking stocks). Low-cost describes the fee. The two often go together because passive funds tend to be cheaper, but you can have a passive approach with high fees (some advised passive portfolios still charge 1.5%+ all-in) or an active approach with relatively low fees. Always check the all-in number.
Less important than most people think. Academic evidence consistently shows that past investment performance is a poor predictor of future performance. The seven questions above are more reliable signals than league tables. That said, a manager with no track record at all is a different matter – ask how long the current investment team has been running the portfolios.
The FCA Register at register.fca.org.uk is the public database of all firms and individuals authorised by the Financial Conduct Authority in the UK. Search for a firm by name or FRN. The Register shows the firm’s permissions, its principals, its registered address, and any past enforcement.
Run the seven questions against each. Where you can’t find a clear answer on a firm’s website, email and ask — how the firm responds is part of the test. SCM Direct’s contact details are below if you want to ask about anything related to investing.
If you want a side-by-side written comparison of how an SCM Direct ISA would look against your current arrangement — same risk profile, fee comparison, holdings comparison — email enquiries@scmdirect.com or call 020 7838 8650. If you would rather just see the SCM Direct ISA proposition directly, the Stocks & Shares ISA page and the Investment Portfolios overview are the next two pages to read.
