{
    "type": "ETF",
    "ucits": true,
    "fund_name": "HSBC FTSE EPRA NAREIT DEVELOPED UCITS ETF",
    "investment_objective": "Track the FTSE EPRA NAREIT Developed Index by investing in shares of companies in the index",
    "primary_asset_class": "Equity (Real Estate Investment Trusts - REITs)",
    "geographic_focus": "Developed markets globally, with significant US exposure (~65%)",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Use of total return swaps up to 10% of assets",
        "Use of contracts for difference up to 10% of assets",
        "Securities lending up to 30% of assets",
        "Exposure to real estate sector and REITs",
        "Potential tracking error due to partial derivative use and securities lending"
    ],
    "classification": "complex",
    "supporting_data": "The Fund primarily uses physical replication investing directly in shares of companies in the FTSE EPRA NAREIT Developed Index, which consists mainly of listed real estate companies and REITs. However, the Fund may invest up to 10% of its assets in total return swaps and contracts for difference, which are derivative instruments used to gain exposure when direct investment is not practical. This derivative usage is inherent to the investment strategy rather than solely for risk management, triggering complexity under MiFID II. The Fund also engages in securities lending up to 30% of assets, which adds counterparty risk. The risk profile is medium-high (category 5 out of 7), reflecting volatility in real estate equities and derivative exposure. There is no leverage or inverse exposure. The Fund is UCITS compliant and physically replicates the index as much as possible, but the presence of derivative instruments (swaps and CFDs) and securities lending, combined with the real estate sector exposure, leads to a classification as complex. The PRIIPs KID does not include a comprehension warning but confirms derivative use and medium-high risk. The monthly factsheet confirms physical replication as primary method but allows up to 10% derivative exposure and securities lending, consistent with the KIID. No capital protection or structured features are present. Fees are straightforward with no performance fees. Overall, the use of derivatives (swaps and CFDs) for gaining exposure, even if limited to 10%, and securities lending introduce complexity elements under MiFID II rules, requiring classification as complex despite the absence of leverage or inverse strategies."
}