{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded swaps",
        "Synthetic replication",
        "Counterparty risk",
        "Non-physical replication",
        "Complex index filters"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco EURO STOXX Optimised Banks UCITS ETF uses unfunded swap agreements to achieve its investment objective, explicitly stated in the KIID and PRIIPs KID. The Fund does not physically replicate the index but holds a basket of equities that differ from the index and swaps the performance of these equities with the counterparty for the index performance. This synthetic replication introduces counterparty risk, as highlighted in multiple risk disclosures. The Fund's risk rating is high (7 in KIID, 6 in PRIIPs), reflecting the complexity and risk of swap usage. There is no leverage or inverse exposure, but the use of unfunded swaps and synthetic replication classifies the ETF as complex under MiFID II. The index tracked is a filtered, capped subset of the STOXX Europe 600 Banks index, adding some complexity to the underlying benchmark. Costs include a swap fee of 10% p.a. in addition to the ongoing charge, indicating derivative-related costs. The PRIIPs KID does not carry a specific comprehension warning but emphasizes the reliance on counterparties and the risk of financial loss if counterparties default. Overall, the synthetic replication via unfunded swaps and associated counterparty risk are the primary drivers of complexity classification despite the absence of leverage or capital protection features."
}