{
    "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 KBW NASDAQ FinTech UCITS ETF uses unfunded swap agreements to achieve its investment objective, explicitly described as synthetic replication. The Fund holds a basket of equities that do not fully replicate the index and swaps the performance of these equities for the index performance via counterparty agreements. The KIID and PRIIPs KID documents both highlight the use of unfunded swaps and the associated counterparty risk, which is a key complexity indicator under MiFID II. There is no leverage or inverse exposure, and derivatives are used inherently as part of the investment strategy rather than solely for risk management, so 'derivatives' is marked false per instructions. The risk profile is high (risk category 7 in KIID, 5/7 in PRIIPs KID), reflecting the volatility and complexity of the synthetic structure and counterparty exposure. The ongoing charges include a swap fee (0.10% p.a.) in addition to the management fee, indicating additional costs related to the derivative structure. The fund is UCITS compliant but the synthetic replication and swap usage make it complex under MiFID II rules. No capital protection or leverage is present, but the synthetic structure and counterparty risk are sufficient to classify the ETF as complex. The underlying index is a straightforward equal-weighted equity index of financial technology companies, so complexity arises from the replication method rather than the underlying assets or index complexity."
}