{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - Bloomberg Commodity Index SF UCITS ETF (hedged to EUR) A-acc",
    "investment_objective": "Capital appreciation by tracking the Bloomberg Commodity Index Total Return (hedged to EUR), passively managed.",
    "primary_asset_class": "Commodity",
    "geographic_sector_focus": "Broad commodity markets including grains, energy, industrial metals, precious metals, livestock sectors and softs.",
    "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",
        "Use of financial derivative instruments (FDIs)",
        "Commodity index complexity and diversification",
        "Swap counterparty credit risk and collateralisation"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through a fully funded total return swap with UBS AG as counterparty, confirmed by the KIID, PRIIPs KID, and the monthly factsheet. The fund invests in FDIs to achieve index exposure rather than physical commodities, exposing investors to counterparty risk. The swap is over-collateralised at 105%, but counterparty risk remains a material factor. The fund does not employ leverage or inverse strategies, and the risk rating is medium (4/7) in the PRIIPs KID but higher (6/7) in the KIID, reflecting volatility and counterparty risk. The underlying index is diversified across multiple commodity sectors with caps and floors on individual commodity weights, adding complexity. The fund is UCITS compliant but the synthetic structure and swap usage classify it as complex under MiFID II. There are no capital protection or structured features, and no leverage or inverse exposure. Costs are straightforward with a TER of 0.19%, no performance fees, but swap-related costs are implicit. The PRIIPs KID does not carry a specific comprehension warning but the synthetic swap structure and counterparty risk are clearly disclosed. Overall, the synthetic replication via total return swaps and counterparty exposure are the main drivers of complexity classification."
}