{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swaps",
        "Counterparty risk exposure",
        "Commodity index with complex roll and maturity structure"
    ],
    "classification": "complex",
    "supporting_data": "The UBS CMCI Composite SF UCITS ETF uses synthetic replication through fully funded total return swaps with UBS AG as the counterparty, confirmed by both the KIID and the fund fact sheet. The fund swaps the performance of the UBS Constant Maturity Commodity Index Total Return against a basket of securities, exposing investors to counterparty risk. The index tracked is a commodity index with exposure across energy, agriculture, livestock, and metals sectors, employing a constant maturity approach to reduce roll costs and contango effects, which adds complexity to the underlying index structure. The fund does not use leverage or inverse strategies, and the risk profile in the PRIIPs KID is moderate (risk level 4 out of 7), but the presence of synthetic replication and swap counterparty risk drives the MiFID II classification as complex. There are no capital protection or structured features, and no leverage is applied. The derivatives are inherent to the investment strategy, not merely for risk management. The fund is UCITS compliant. The complexity arises primarily from the synthetic replication method, the use of total return swaps, and the complexity of the underlying commodity index with constant maturity roll mechanics."
}