{
    "type": "ETF",
    "ucits": true,
    "fund_name": "iShares S&P 500 Swap UCITS ETF USD (Dist)",
    "investment_objective": "To achieve a return reflecting the net total return of the S&P 500 Index through a combination of capital growth and income.",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded total return swaps",
        "Counterparty risk",
        "Synthetic replication"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses unfunded total return swaps as the primary method to achieve exposure to the S&P 500 Index, indicating synthetic replication. The KIID and PRIIPs KID explicitly state the use of financial derivative instruments (FDIs), including swaps, options, and non-deliverable futures, to gain exposure. The Fund invests in a portfolio of equities whose returns are paid to swap counterparties, confirming the unfunded swap structure. The risk profile is rated 6 out of 7, reflecting medium-high risk largely due to derivative and counterparty risks. The Fund discloses significant counterparty risk exposure and reliance on counterparties to deliver benchmark performance. There is no leverage or inverse exposure, and the Fund is UCITS compliant. Costs are low and straightforward, with no performance fees, but securities lending revenue sharing is noted. The underlying index is a standard large-cap US equity index, which is not complex, but the synthetic swap structure and counterparty risk elevate the complexity under MiFID II. The PRIIPs KID does not include a comprehension warning but confirms the derivative usage and risk level. The monthly factsheet confirms the synthetic swap methodology and counterparty risk, with no leverage or structured capital protection features. Overall, the synthetic replication via unfunded total return swaps and associated counterparty risk are the main drivers of the complex classification under MiFID II, despite the straightforward underlying index and absence of leverage.",
    "risk_level": 6
}