{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Irl) Fund Solutions plc - UBS CMCI ex-Agriculture SF UCITS ETF",
    "investment_objective": "Capital appreciation by tracking the UBS CMCI Ex-Agriculture Ex-Livestock Capped Index Total Return",
    "primary_asset_class": "Commodity",
    "geographic_sector_focus": "Global commodity markets excluding agriculture and livestock, focused on energy and metals sectors",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Counterparty risk exposure to UBS AG",
        "Use of financial derivative instruments (FDIs)",
        "Commodity futures index with roll and contango effects"
    ],
    "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 the monthly factsheet. The Fund invests primarily in FDIs to swap the performance of the commodity index to the Fund, rather than direct physical holdings. This introduces counterparty risk, explicitly disclosed as a material risk. The index tracked is a commodity futures index with multiple maturities and components, implying complexity due to roll costs, contango/backwardation effects, and non-linear performance drivers. The Fund is UCITS compliant but does not use leverage or inverse strategies. The risk profile is high (category 6 in KIID) due to 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 presence of swaps and derivative instruments as an inherent part of the investment strategy, combined with counterparty risk and the complexity of the underlying commodity futures index, drives the MiFID II classification as complex. There is no leverage or capital protection mechanism, but the synthetic structure and derivative use are sufficient to classify the ETF as complex under MiFID II rules."
}