{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi CAC 40 UCITS ETF Acc",
    "investment_objective": "Replicate the EUR-denominated CAC 40 Gross Total Return Index (gross dividends reinvested) by direct replication or sampling",
    "primary_asset_class": "Equity",
    "geographic_focus": "France / European Union",
    "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 fund physically replicating the CAC 40 index primarily by direct purchase of underlying securities with possible sampling. The KIID and factsheet confirm physical replication. 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. The derivatives exposure is limited to risk management (securities lending) rather than inherent to the investment strategy, so 'derivatives' is false. There is no leverage or inverse exposure. The risk profile is medium-high (5/7), reflecting market risk and some counterparty risk. No capital protection or structured features are present. Costs are straightforward with no performance fees. Despite physical replication and straightforward index tracking, the presence of OTC swaps and counterparty risk exposure triggers MiFID II complexity classification. The swap usage, even if limited and for securities lending, introduces complexity due to counterparty risk and derivative instrument involvement. The fund's risk disclosures highlight counterparty risk and liquidity risk beyond normal market conditions. Therefore, under MiFID II, this ETF is classified as complex primarily due to the use of OTC swaps and associated counterparty risk, despite its physical replication and straightforward equity index exposure."
}