{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded swaps",
        "Counterparty risk",
        "Synthetic replication",
        "Non-physical replication",
        "Use of equities not in index"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco NASDAQ-100 Swap UCITS ETF uses unfunded swap agreements to synthetically replicate the NASDAQ-100 Index performance. The Fund holds a basket of equities and equity-related securities that do not fully replicate the index, and swaps the performance of these holdings with the counterparty to achieve index returns. The KIID explicitly states the use of unfunded swaps and counterparty risk exposure. The PRIIPs KID confirms the reliance on counterparties to deliver index performance and highlights the risk of financial loss if counterparties default. The monthly factsheet reiterates the synthetic replication method, swap fee, and counterparty risk, confirming the derivative usage is inherent to the strategy rather than incidental. There is no leverage or inverse exposure. The risk rating is 6 out of 7, indicating a higher risk profile consistent with complexity. The use of synthetic replication via unfunded swaps, counterparty exposure, and non-physical replication are key MiFID II complexity drivers. Although the fund is UCITS compliant and has a straightforward index-tracking objective, the inherent swap structure and counterparty risk classify it as complex under MiFID II rules."
}