{
    "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 costs 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. The index tracked is a commodity futures index excluding agriculture and livestock, with exposure to energy and metals sectors, which inherently involves complexities such as roll costs, contango, and backwardation. The Fund carries significant counterparty risk as the swap counterparty's failure would materially impact the Fund. The risk profile is high (category 6 in KIID) reflecting volatility and derivative exposure. There is no leverage or inverse exposure, but the synthetic swap structure and counterparty risk are key complexity drivers. The PRIIPs KID classifies the product as medium risk (4/7) but notes the product is not capital protected and may lose value. The Fund is UCITS compliant but the synthetic swap usage and counterparty exposure make it complex under MiFID II. No capital protection or structured features are present. Costs are straightforward with no performance fees but include swap-related costs embedded in ongoing charges. Overall, the synthetic replication via total return swaps and counterparty risk exposure are the main factors driving the complex classification despite the absence of leverage or inverse features."
}