{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - UBS CMCI Composite SF UCITS ETF",
    "investment_objective": "Capital appreciation by tracking the UBS Constant Maturity Commodity Index Total Return",
    "primary_asset_class": "Commodity",
    "geographic_sector_focus": "Broad commodity markets including energy, agriculture, livestock, and metals sectors",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Counterparty risk exposure to UBS AG",
        "Investment in derivatives rather than physical commodities",
        "Complex commodity index with constant maturity roll strategy",
        "Potential liquidity and operational risks",
        "No leverage but swap-based exposure"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses synthetic replication through a fully funded total return swap with UBS AG as counterparty, exposing investors to counterparty risk. The Fund invests primarily in financial derivative instruments (FDIs) to achieve the performance of the UBS Constant Maturity Commodity Index Total Return, rather than direct physical commodities, which is a key complexity indicator under MiFID II. The index tracked is a complex commodity index that employs a constant maturity roll strategy to minimize negative roll yield and contango effects, adding to the complexity. The risk profile is high (category 6 in KIID), reflecting volatility and counterparty risk. There is no leverage or inverse exposure, but the use of swaps and derivatives as an inherent part of the investment strategy mandates classification as complex. Costs are straightforward with no performance fees, but swap-related costs are embedded. The PRIIPs KID confirms the synthetic swap structure and highlights counterparty risk and medium risk level (4/7), but the KIID risk rating of 6 and the synthetic swap usage dominate the complexity assessment. The fund is UCITS compliant but the synthetic replication and derivative use for index exposure make it complex under MiFID II rules."
}