{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded total return swaps",
        "Counterparty risk",
        "Derivative instruments for investment purposes",
        "Securities lending",
        "Index concentration risk"
    ],
    "classification": "complex",
    "supporting_data": "The Global X U.S. Infrastructure Development UCITS ETF aims to replicate the Indxx U.S. Infrastructure Development v2 Index primarily through investing in equity securities. However, the KIID explicitly states the use of financial derivative instruments, including total return 'unfunded' OTC swaps and exchange-traded equity futures for investment purposes. The presence of unfunded swaps and counterparty risk disclosures are key complexity indicators under MiFID II. The fund does not use leverage or inverse strategies, and derivatives are not used for mere risk management but as an inherent part of the replication strategy, which mandates classification as complex. The risk profile is medium-high (risk category 6 in KIID, 5 in PRIIPs), reflecting volatility and derivative-related risks. The fund also engages in securities lending, which adds operational complexity. The replication method is synthetic, not physical, confirmed by the explicit swap usage. No capital protection or structured features are present. Costs are straightforward with no performance fees, but swap and derivative costs are implicit. The PRIIPs KID does not carry a specific comprehension warning but confirms the medium-high risk and derivative usage. The monthly factsheet (not fully provided) is expected to confirm swap usage and derivative exposure. Overall, the synthetic replication via unfunded total return swaps and associated counterparty risk are the main drivers of complexity under MiFID II, despite the fund's UCITS status and absence of leverage or structured capital protection."
}