{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Sampling of corporate bonds, FX hedging, securities lending",
    "classification": "non-complex",
    "supporting_data": "The Invesco BulletShares 2028 USD Corporate Bond UCITS ETF aims to replicate the Bloomberg 2028 Maturity USD Corporate Bond Screened Index using a sampling technique rather than full replication. The Fund invests directly in USD denominated investment grade corporate bonds with fixed maturity in 2028. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy. Derivatives are only used for risk management, cost reduction, or generating additional capital or income, which is typical and does not imply complexity under MiFID II. The Fund employs FX forwards for currency hedging between the base currency (USD) and share class currency (GBP), which is a standard risk management tool and not an inherent complexity driver. The Fund does engage in securities lending, but this is disclosed transparently and does not add to complexity classification. The risk profile is moderate (risk category 3), below the threshold (4-5) often associated with complex products. There is no leverage, inverse or amplified exposure. The underlying assets are straightforward fixed-rate corporate bonds, liquid and transparent, with no contingent convertible bonds, CLOs, or structured products. No capital protection or structured features are present. The Fund is UCITS compliant, which imposes regulatory constraints limiting complexity. No significant counterparty risk is disclosed beyond normal securities lending and FX forward counterparties. Overall, the ETF exhibits a clear, linear relationship to the underlying index performance, with minimal derivative use for hedging only, and no synthetic replication or leverage. Therefore, it is classified as non-complex under MiFID II."
}