{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - Bloomberg Commodity Index SF UCITS ETF (hedged to CHF)",
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Counterparty risk exposure to UBS",
        "Use of financial derivative instruments",
        "Commodity index with multiple sectors and roll costs"
    ],
    "classification": "complex",
    "supporting_data": "The ETF tracks the Bloomberg Commodity Index Total Return via a fully funded total return swap with UBS AG as counterparty, indicating synthetic replication. The fund invests in financial derivative instruments (FDIs) and swaps the index performance with UBS, exposing investors to counterparty risk. The fund is UCITS compliant but uses synthetic replication rather than physical. There is no leverage or inverse exposure, but the use of swaps and derivatives as an inherent part of the strategy classifies it as complex under MiFID II. The risk/reward indicator is 6 (high risk), reflecting volatility and counterparty risk. The PRIIPs KID confirms medium risk (4/7) but notes counterparty credit risk and no capital protection. The factsheet confirms the swap is fully funded and over-collateralised by 105%, but the presence of swap counterparty risk and synthetic replication are key complexity drivers. The commodity index tracked is diversified but involves roll costs and contango/backwardation effects typical of commodity indices, adding to complexity. No leverage or inverse features are present. Costs are straightforward with a TER of 0.19% and no performance fees. Overall, the synthetic replication via total return swaps and counterparty risk exposure make this ETF complex under MiFID II despite the absence of leverage or structured capital protection features."
}