The Financial Services Compensation Scheme is considering whether it will be involved in compensation for clients of HD Administrators.
This firm, which offered a Sipp account called the HD Sipp, went into liquidation in June 2012.
Two HD Sipp trustees were arrested in March 2012 by Nottinghamshire Police who were working with the Serious Fraud Office to investigate fraud allegations.
One of these trustees was also a partner at HD Administrators.
The Sipp account is now managed by Mattioli Woods and customers are able to access and deal with their investments. At the time, Mattioli Woods said the HD Sipp had around 40 active members.
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The FSCS is now reviewing whether the firm is liable for investors' claims.
It said: "FSCS is reviewing whether the firm is liable for investors' claims and will need to consider the investigation of other interested parties such as the administrator and Serious Fraud Office.
"FSCS will provide further update as soon as the position is clearer. At that time we will also confirm any claims processes for clients of HD Administrators who have not yet made a claim to FSCS."