{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via OTC derivatives",
        "Counterparty risk from swaps",
        "Currency hedging using forwards",
        "Use of structured notes",
        "High volatility risk category"
    ],
    "classification": "complex",
    "supporting_data": "The UBS Factor MSCI USA Quality Screened UCITS ETF uses a synthetic replication method, as it may gain exposure to the MSCI USA Quality Advanced Target Select 100% Hedged to EUR Index either through direct investments or derivatives, particularly OTC derivatives such as swaps. The KIID explicitly mentions the use of OTC derivatives and associated counterparty risk, mitigated by a collateral policy. The fund employs currency hedging via foreign currency forwards, which are derivatives but used for risk management rather than inherent strategy, so derivatives are marked false. However, the presence of funded or unfunded swap agreements and counterparty exposure classifies the fund as complex under MiFID II. There is no leverage or inverse exposure. The fund invests predominantly in shares and transferable securities but also in structured notes listed on regulated markets, adding to complexity. The risk profile is high (category 6 in KIID, 4 in PRIIPs KID), reflecting high volatility and derivative-related risks. Costs are straightforward with no performance fees, but derivative trading costs and collateral management risks are noted. The PRIIPs KID does not include a comprehension warning but confirms medium risk and derivative use. Overall, the synthetic replication via OTC swaps and counterparty risk are the main drivers of complexity classification despite the fund being UCITS compliant and having no leverage."
}