{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Market Access Rogers International Commodity Index UCITS ETF",
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreement",
        "Counterparty risk exposure",
        "Commodity futures based index",
        "Use of derivatives inherent to strategy"
    ],
    "classification": "complex",
    "supporting_data": "The Fund uses a synthetic replication method by entering into a Swap Agreement with BNP Paribas S.A. to exchange the performance of a portfolio of securities against the Rogers International Commodity Index\u00ae, which tracks 38 commodities via futures contracts. The KIID and PRIIPs KID explicitly mention the use of derivative agreements (swaps) as an inherent part of the investment strategy, not merely for risk management. The Fund carries counterparty risk related to the swap counterparty, which is highlighted as a significant risk. The underlying index is based on commodity futures, which are complex instruments subject to contango, backwardation, and volatility. The risk profile is high (6 in KIID, 5 in PRIIPs), reflecting the complexity and volatility of commodity futures exposure. There is no leverage or inverse exposure, but the synthetic swap structure and derivative use for replication classify the Fund as complex under MiFID II. The Fund is UCITS compliant but the synthetic replication and counterparty risk are key complexity drivers. No capital protection or structured features are present. Costs are straightforward with no performance fees, but the ongoing charge includes swap-related costs. The PRIIPs KID indicates the Fund is suitable only for investors with knowledge of ETFs and derivatives, reinforcing complexity. The monthly factsheet confirms synthetic replication and swap usage with BNP Paribas and Barclays Bank as counterparties. Overall, the Fund\u2019s use of swaps, derivative-based index exposure, and counterparty risk make it complex under MiFID II rules."
}