{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Unfunded Swaps",
    "classification": "complex",
    "supporting_data": "The Invesco Health Care S&P US Select Sector UCITS ETF uses synthetic replication via unfunded swap agreements with approved counterparties to achieve its investment objective. The Fund holds a basket of equities that do not fully replicate the index and swaps the performance of these equities for the performance of the S&P Select Sector Capped 20% Health Care Index. The KIID and PRIIPs documents explicitly mention the use of unfunded swaps and counterparty risk, which are key complexity indicators under MiFID II. There is no leverage or inverse exposure, and derivatives are used only as part of the synthetic replication strategy, not for risk management alone. The risk profile is medium (risk category 4-6 depending on document), reflecting market and counterparty risks. The fund is UCITS compliant, but the synthetic structure and counterparty exposure drive the classification as complex. No capital protection or structured features are present. Costs are straightforward with no performance fees, but swap fees are embedded in the ongoing charges. The PRIIPs KID does not carry a specific comprehension warning but highlights counterparty risk and the lack of capital guarantee. The factsheet confirms synthetic replication and swap usage, with no leverage or complex underlying assets beyond equities. Overall, the synthetic replication via unfunded swaps and associated counterparty risk are the main drivers of complexity under MiFID II."
}