{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc \u2013 CMCI Future Commodity SF UCITS ETF",
    "investment_objective": "Capital appreciation by tracking the UBS CMCI Future Commodity Index Total Return",
    "primary_asset_class": "Commodity derivatives",
    "geographic_sector_focus": "Global commodities across energy, industrial metals, precious metals, agriculture and livestock sectors",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Counterparty risk exposure to UBS AG",
        "Use of financial derivative instruments (FDIs)",
        "Commodity futures with ecological-social scoring",
        "Potential liquidity risk in commodity markets"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses a fully funded total return swap with UBS AG as counterparty to synthetically replicate the UBS CMCI Future Commodity Index. The KIID explicitly states the Fund invests in financial derivative instruments (FDIs) and swaps, with UBS as counterparty, exposing investors to counterparty risk. The replication method is synthetic, confirmed by the factsheet. There is no leverage or inverse exposure, but the use of swaps and derivatives as an inherent part of the investment strategy classifies the ETF as complex under MiFID II. The risk profile is high (category 6 out of 7), reflecting volatility and counterparty risk. The PRIIPs KID confirms the medium-high risk rating (5 out of 7) and highlights the credit risk of the swap counterparty. The Fund invests in commodity futures with ecological and social criteria, which adds complexity to the underlying index. The Fund is UCITS compliant but the synthetic swap structure and counterparty exposure are key complexity drivers. No capital protection or leverage is present. Costs include swap fees and derivative costs embedded in the TER. The Fund is not suitable for investors with a short investment horizon (recommended holding period 7 years). Overall, the synthetic replication via total return swaps and counterparty risk exposure are decisive factors for classifying this ETF as complex under MiFID II."
}