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On May 19, the Commodity Futures Trading Commission’s Global Markets Advisory Committee approved a report that contains several recommendations for action by the CFTC with respect to the implementation of its initial margin (IM) rules for uncleared swaps. The recommendations are focused on the unique challenges faced by small end users of swaps and entities that engage in swap activity through separate managed accounts (SMAs). The report recommends that the CFTC take all of the following actions: issue Interpretive Guidance to confirm that a swap dealer can continue to trade with an SMA client in the case of an inadvertent…