{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - UBS CMCI Commodity Carry ex-Agriculture SF UCITS ETF",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Leverage embedded in underlying index (2.5x leveraged)",
        "Counterparty risk to UBS AG",
        "Exposure to complex commodity indices with futures roll and carry strategies"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses synthetic replication through a fully funded total return swap with UBS AG as counterparty, confirmed by the KIID, PRIIPs KID, and monthly factsheet. The Fund tracks a 2.5x leveraged commodity index that provides exposure to the difference in performance of two commodity indices, employing a daily rolling futures methodology to optimize roll yields and reduce carry costs. This leverage and the use of swaps introduce complexity and counterparty risk. The Fund's risk profile is high (category 6 in KIID), reflecting volatility and counterparty risk. The PRIIPs KID classifies the risk as medium (4/7) but notes the product is not capital protected and may lose value. The factsheet explicitly states the Fund synthetically replicates the index via a swap, with collateral posted in government bonds and cash, confirming funded swap structure. The Fund invests in derivatives as an inherent part of its strategy, not merely for risk management. There is no inverse exposure, but leverage and swap usage are clear complexity drivers. The underlying index's complexity, leverage, and swap counterparty risk make the Fund complex under MiFID II rules despite UCITS compliance and relatively moderate ongoing charges. No capital protection or structured features are present, but the leverage and synthetic replication are decisive factors."
}