{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco NASDAQ-100 Swap UCITS ETF uses unfunded swap agreements as its primary replication method, explicitly described as synthetic replication. The Fund does not physically replicate the NASDAQ-100 Index but instead holds a basket of equities and equity-related securities that differ from the index, exchanging performance via swap contracts with approved counterparties. The use of unfunded swaps introduces counterparty risk, which is highlighted multiple times in the KIID and PRIIPs KID documents. The Fund's risk profile is rated 6 out of 7, indicating a medium-high risk level, partly due to derivative counterparty exposure. 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 Fund is UCITS compliant. Costs include a swap fee (0.05% p.a.) in addition to the ongoing charge, reflecting derivative-related costs. The PRIIPs KID does not include a comprehension warning but emphasizes the complexity arising from swap usage and counterparty risk. The monthly factsheet confirms the synthetic replication via swaps and the presence of swap fees, reinforcing the complexity classification. No capital protection or structured features are present, and the underlying assets are equities, not complex structured products. However, the synthetic replication via unfunded swaps and associated counterparty risk are sufficient to classify this ETF as complex under MiFID II rules."
}