{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - UBS CMCI Commodity Carry SF UCITS ETF",
    "replication_method": "synthetic",
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Leverage embedded in index (2.5x leveraged exposure)",
        "Counterparty risk from swap with UBS AG",
        "Complex commodity index exposure (difference of two commodity indices)",
        "Use of collateralized swap with government bonds and cash",
        "Potential tracking error due to swap and index complexity"
    ],
    "classification": "complex",
    "supporting_data": "The Fund is a UCITS ETF that synthetically replicates the UBS CM-BCOM Outperformance Strategy Index ex-Precious Metals 2.5 Leveraged Net of Cost Total Return via a fully funded total return swap with UBS AG as counterparty. The index itself uses leverage (2.5x) and provides exposure to the difference in performance of two commodity indices, not direct commodity prices, adding complexity. The Fund invests in financial derivative instruments (FDIs) and swaps, with collateral posted in government bonds and cash. The Fund's performance depends on the swap counterparty's ability to perform, introducing significant counterparty risk. The risk profile is medium (category 4 in KIID, 3 in PRIIPs KID), but the synthetic replication, leverage embedded in the index, and derivative counterparty exposure are key complexity drivers under MiFID II. The PRIIPs KID classifies the product as suitable for retail investors with basic financial understanding but warns of potential losses and counterparty risk. The factsheet confirms synthetic replication via a fully funded total return swap and collateral management. No capital protection or inverse/leverage beyond the index leverage is present. The use of derivatives is inherent to the strategy, not just risk management. Therefore, the Fund meets MiFID II criteria for a complex financial instrument."
}