{
    "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 swaps",
        "Counterparty exposure to UBS AG",
        "Use of financial derivative instruments as core investment method",
        "Commodity index with complex roll and maturity structure",
        "Potential liquidity and operational risks related to derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses synthetic replication through fully funded total return swaps with UBS AG as counterparty, explicitly stated in the KIID and fact sheet. The Fund invests primarily in financial derivative instruments (FDIs) to swap the performance of the UBS Constant Maturity Commodity Index Total Return to the Fund, rather than direct physical holdings of commodities or futures. The index tracked is a complex commodity index with exposure to multiple sectors and maturities, designed to minimize roll costs and contango effects, which adds complexity. The Fund carries significant counterparty risk as the performance depends on UBS fulfilling swap obligations. The risk profile is high (category 6 in KIID), reflecting volatility and derivative risks. The PRIIPs KID confirms the use of swaps and derivative instruments as inherent to the strategy, not merely for risk management, and highlights counterparty risk and lack of capital protection. There is no leverage or inverse exposure, but the synthetic swap structure and derivative use classify the ETF as complex under MiFID II. The Fund is UCITS compliant but the synthetic replication and swap usage are key complexity drivers. Costs are straightforward with no performance fees but include derivative-related costs. The recommended holding period is 5 years, indicating medium to long-term investment horizon due to complexity and volatility. Overall, the synthetic replication via total return swaps and counterparty risk are decisive factors for the complex classification."
}