{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi FTSE Italia PMI PIR 2020 UCITS ETF Acc",
    "investment_objective": "Replicate the EUR-denominated FTSE Italia PIR PMI Net Tax Index, representing small- and mid-cap Italian stocks",
    "primary_asset_class": "equity",
    "geographic_focus": "Italy (Eurozone)",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC swap for securities lending counterparty risk",
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS-compliant equity ETF physically replicating the FTSE Italia PIR PMI Net Tax Index, focusing on Italian small- and mid-cap stocks. The KIID and factsheet confirm physical replication with direct investment in underlying securities and use of sampling techniques. However, the factsheet explicitly states the use of an OTC swap with Morgan Stanley Bank AG and Societe Generale for securities lending purposes, with counterparty exposure capped at 10% of total assets. Although derivatives are used only for risk management (securities lending), the presence of OTC swaps and counterparty risk exposure triggers MiFID II complexity classification. There is no leverage, inverse or structured capital protection features. The risk profile is medium (4/7), consistent with equity market risk. Costs are straightforward with no performance fees. The PRIIPs KID does not include a comprehension warning, and the product is intended for investors with basic knowledge. Despite this, MiFID II rules classify any ETF with swap usage as complex. Therefore, the classification is complex primarily due to the OTC swap usage and associated counterparty risk, even though the replication is physical and no leverage is employed."
}