{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via fully funded total return swap",
        "Counterparty exposure to UBS AG",
        "Use of financial derivative instruments (FDIs)",
        "Swap collateralization with government bonds and cash"
    ],
    "classification": "complex",
    "supporting_data": "The UBS USD Overnight Rate SF UCITS ETF uses synthetic replication through a fully funded total return swap with UBS AG as counterparty. The KIID explicitly states the Fund invests in financial derivative instruments (FDIs) and swaps the performance of the Solactive SOFR Daily Total Return Index against a basket of securities held by the Fund. The factsheet confirms the swap is fully funded and collateralized by G10 government bonds, supranational bonds, and cash, indicating counterparty risk and derivative usage as inherent to the investment strategy. There is no leverage or inverse exposure. The Fund is UCITS compliant. The risk profile is low (category 1), but the presence of synthetic replication and swap counterparty risk drives the MiFID II classification as complex. The Fund\u2019s strategy and structure involve derivative instruments as an inherent element, not merely for risk management. No capital protection or structured features are present. The complexity arises mainly from the synthetic replication and counterparty exposure, which may not be easily understood by retail investors despite the low risk rating. No references to leverage, inverse, or complex underlying assets like contingent bonds were found. The index tracked (SOFR Daily Total Return) is straightforward but the use of swaps and collateralized counterparty exposure triggers complexity under MiFID II."
}