{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication",
        "Total return swap",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The UBS (Irl) Fund Solutions plc - S&P 500 SF UCITS ETF uses synthetic replication via a fully funded total return swap with UBS AG, London Branch as the counterparty. The fund does not invest directly in the underlying securities to replicate the S&P 500 Net Total Return Index but swaps the index performance with UBS in exchange for the performance of a basket of securities. This swap structure exposes the fund to counterparty risk, explicitly noted in the KIID and fact sheet. The fund is UCITS compliant but uses derivatives inherently as part of its investment strategy, not merely for risk management, which mandates classification as complex under MiFID II. There is no leverage or inverse exposure, and the risk profile is medium (4 out of 7 in PRIIPs KID, 6 out of 7 in KIID), reflecting the counterparty and operational risks associated with the swap. Costs are straightforward with no performance fees but include swap-related costs embedded in the TER. The underlying index is a broad, liquid equity index (S&P 500), so underlying asset complexity is low, but the synthetic swap structure and counterparty exposure drive complexity. No capital protection or structured features are present. The PRIIPs KID does not carry a comprehension warning but confirms the use of swaps and counterparty risk. Therefore, despite a medium risk rating and no leverage, the synthetic replication via total return swaps and counterparty risk exposure classify this ETF as complex under MiFID II."
}