{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Unfunded Swaps",
    "classification": "complex",
    "supporting_data": "The Invesco MSCI USA UCITS ETF uses unfunded swap agreements as a core part of its investment strategy to synthetically replicate the MSCI USA Index. The KIID explicitly states the use of unfunded swaps with counterparty exposure, and the fund holds a basket of equities that do not fully replicate the index. The PRIIPs KID confirms the synthetic replication method and highlights counterparty risk related to swaps. The monthly factsheet reiterates the synthetic replication and swap fee of 0.07% p.a., confirming swap usage. There is no leverage or inverse exposure, and derivatives are used only as part of the synthetic replication, not for risk management alone. The fund is UCITS compliant. The risk profile is medium-high (risk category 5-6), reflecting the complexity and counterparty risk inherent in synthetic replication. The presence of unfunded swaps and counterparty risk triggers the MiFID II classification as complex, despite the fund's straightforward equity exposure and lack of leverage. No capital protection or structured features are present. Costs are simple with no performance fees, but swap fees are charged. Overall, the synthetic replication via unfunded swaps and associated counterparty risk are the primary drivers of complexity under MiFID II."
}