{
    "type": "ETF",
    "ucits": true,
    "fund_name": "L&G Longer Dated All Commodities UCITS ETF",
    "investment_objective": "Track the Bloomberg Commodity Index 3 Month Forward Total Return",
    "primary_asset_class": "Commodity",
    "geographic_sector_focus": "Global commodities across Energy, Precious Metals, Industrial Metals, Livestock, Grains, Softs",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded total return swaps",
        "Commodity futures exposure via swaps",
        "Roll return and collateral return components",
        "Counterparty risk from swap counterparties",
        "Volatility and complexity of commodity futures markets"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via unfunded total return swap agreements with one or more swap counterparties (investment banks). The Fund does not physically hold commodity futures but receives the Index performance through swaps, retaining investor subscription money and investing it in low risk assets. The Index tracked is a longer-dated commodity futures index with exposure to multiple commodity sectors and includes complex features such as roll returns and collateral returns. The KIID and PRIIPs KID explicitly mention counterparty risk, swap counterparty failure risk, and derivative use as inherent to the strategy. The risk rating is 6/7, indicating a higher risk profile consistent with complexity. The fact sheet confirms synthetic replication, unfunded swap structure, and commodity futures exposure via derivatives. There is no leverage or inverse exposure, but the use of total return swaps and commodity futures with roll and collateral return components, plus counterparty risk, drive the MiFID II classification as complex. The PRIIPs KID also notes that the product is designed for investors familiar with commodity futures and the index features, implying a need for specific investment knowledge. No capital protection or structured features are present, but the derivative and swap usage, plus the complexity of the underlying commodity futures index, are sufficient to classify the ETF as complex under MiFID II rules."
}