{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco S&P 500 Scored & Screened UCITS ETF uses unfunded swap agreements to synthetically replicate the performance of the S&P 500 Scored & Screened Index. The Fund holds a basket of equities that do not fully replicate the index and swaps the performance of these equities with the counterparty to achieve index returns. The use of unfunded swaps introduces counterparty risk, as explicitly disclosed in the KIID and PRIIPs KID documents. There is no leverage or inverse exposure, and derivatives are used as an inherent part of the investment strategy rather than solely for risk management, so 'derivatives' is marked false per instructions. The risk profile is medium-high (risk category 5-6), reflecting the synthetic structure and counterparty exposure. Costs include a swap fee (0.11% p.a.) in addition to the ongoing charge (0.09% p.a.), indicating complexity in cost structure. The underlying index is a screened ESG variant of the S&P 500, which is a broad, liquid equity index, so underlying asset complexity is low. However, the synthetic replication via unfunded swaps and associated counterparty risk are key complexity drivers under MiFID II. There is no capital protection or leverage. The PRIIPs KID does not carry a specific comprehension warning but confirms the synthetic swap structure and counterparty risk. Overall, the synthetic replication using unfunded swaps and counterparty risk exposure classify this ETF as complex under MiFID II."
}