{
    "type": "ETF",
    "ucits": true,
    "fund_name": "AMUNDI ETF MSCI EMU HIGH DIVIDEND UCITS ETF",
    "investment_objective": "Replicate as closely as possible the performance of the MSCI EMU High Dividend Yield Strategy Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Eurozone (European Economic and Monetary Union countries)",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps (TRS) to exchange the performance of the assets held by the fund for that of the MSCI EMU High Dividend Yield Index. The KIID and PRIIPs KID explicitly mention the use of swap agreements and derivative instruments as an inherent part of the investment strategy, not merely for risk management. The fund is UCITS compliant and invests primarily in Eurozone equities with a passive index-tracking objective. There is no leverage or inverse exposure. The risk profile is medium (4 out of 7), with specific counterparty risk disclosures related to the swap counterparties. The ongoing charges are straightforward with no performance fees, but swap usage introduces counterparty risk and complexity. The synthetic replication method and swap usage are key drivers of the MiFID II complexity classification, as investors may find it difficult to fully understand the implications of counterparty risk and derivative exposure inherent in the structure. No capital protection or structured features are present. The underlying assets are liquid equities, but the synthetic structure and swap counterparty risk elevate complexity. No leverage or inverse exposure is present, and derivatives are used as an inherent element of the strategy, not just for hedging. The PRIIPs KID does not carry a specific comprehension warning but confirms the use of derivatives and counterparty risk. The factsheet confirms synthetic replication and swap usage, with no leverage or complex underlying assets like contingent bonds. Therefore, under MiFID II, the ETF is classified as complex due to its synthetic replication and swap usage."
}