The FCA published its finalised guidance on the fairness of variation terms in financial services consumer contracts under the Consumer Rights Act 2015 on 19 December 2018. While there weren’t many substantial changes from the FCA’s draft guidance, a number of helpful clarifications were made. Importantly, the FCA has emphasised that the responsibility for ensuring that consumer contracts are fair lies with senior managers. Firms will want to review their variation clauses in the light of the final guidance to ensure they reflect best practice. Click here to read the full piece.