{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded total return swaps",
        "Counterparty risk exposure",
        "Synthetic replication",
        "Derivative instruments used for index exposure"
    ],
    "classification": "complex",
    "supporting_data": "The iShares NASDAQ 100 Swap UCITS ETF uses synthetic replication via unfunded total return swaps to achieve exposure to the NASDAQ 100 Index. The Fund invests its cash in a substitute basket of global developed market equity securities and pays the return of this basket to swap counterparties, enabling exposure to the Index. This swap-based structure introduces counterparty risk, explicitly noted in the KIID and PRIIPs documents. The Fund is UCITS compliant but uses derivatives as an inherent part of its investment strategy rather than solely for risk management, which mandates classification as complex under MiFID II. There is no leverage or inverse exposure. The risk profile is medium-high (risk level 5-6), reflecting the derivative usage and counterparty risk. Costs are straightforward with a TER of 0.20%, no performance fees, and no leverage-related fees. The synthetic replication and swap usage, combined with counterparty risk and derivative sensitivity, are the primary drivers of complexity classification despite the Fund's straightforward equity index objective and absence of leverage or structured capital protection features."
}