Yesterday's announcement, jointly by the FCA and TPR, is a welcome (if implicit) recognition that a pause is called for.
Back in the Autumn, Andrew Bailey said the FCA would be publishing its pensions' strategy by the end of the year. As I wrote at the time, the regulator's workload and the complexity of the subject made this unlikely. Now it has been pushed back further. Whether or not Carillion (and British Steel) was the final straw, this is probably the first example of Brexit forcing the regulator to kick the can down the road.
In this case, however, a pause is the right answer. Pensions' regulation has been a patchwork of complexity for a long time, made more difficult by multiple factors - from corporate raiding of pension funds (going back to Maxwell etc.), to pensions' high political profile and the disparate landscape of regulatory responsibility (as well as the two regulators, the DWP is also in the mix). Coming up with a coherent strategy was always going to take more time.
At university, a long time ago, I learned to be sceptical of what was termed the Whig view of history, essentially the notion that English history was a story of continual progress. The truth, however disputable, is always more difficult and layered.
In the case of pensions' regulation, the optimism that surrounded the 2014 budget announcement of pension freedom was always premature. Whatever your view of the reform, it added to the difficulty of regulation.
In financial services, regulation - partly due to the doctrine of proportionality - is almost invariably responsive rather than forward looking. And too often, success is declared (typically by all sides) on the basis of what is essentially a closing of the door after the event - SM&CR is a recent example.
Over the last 30 years, the effectiveness of pensions' regulation, largely due to events outside its control, has arguably gone back a couple of steps. Deciding to pause and regroup may be counter intuitive. But, with the regulators working together and undertaking wider consultation, it is almost certainly the best way to move forward.
The Financial Conduct Authority (FCA) and The Pensions Regulator (TPR) are working together on a pensions regulatory strategy, which will set out how we will work together to tackle the key risks facing the pensions sector in the next 5-10 years.