{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Invesco FTSE RAFI Emerging Markets UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco FTSE RAFI Emerging Markets UCITS ETF aims to replicate the FTSE RAFI Emerging Markets Index by physically holding the underlying shares of approximately 350 companies domiciled in emerging markets. The KIID and PRIIPs KID explicitly state that the Fund uses physical replication, holding all or substantially all constituents of the index in their respective weightings. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy, only that derivatives may be used for risk management purposes, which does not trigger complexity under MiFID II. The Fund does not employ leverage, inverse or amplified exposure, nor does it invest in complex underlying assets such as contingent convertible bonds or CLOs. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID risk scale reflecting emerging market risk), consistent with direct equity exposure in emerging markets rather than complexity. The Fund engages in securities lending, but this is a common practice and does not itself imply complexity. Costs are straightforward with a single ongoing charge of 0.49% and no performance fees or swap fees. The monthly factsheet confirms physical replication and no use of synthetic structures or swaps. The index tracked is a fundamental index based on sales, cash flow, book value, and dividends averaged over five years, which is more complex than a simple market cap index but does not in itself render the ETF complex under MiFID II. There is no capital protection or structured product features. No comprehension warnings or specific retail investor suitability warnings indicating complexity are present in the PRIIPs KID. Therefore, the ETF is classified as non-complex under MiFID II."
}