{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swaps",
        "Counterparty risk exposure",
        "Use of derivatives as inherent part of strategy"
    ],
    "classification": "complex",
    "supporting_data": "The fund is a UCITS ETF that aims to track the Solactive SONIA Daily Total Return Index by using financial contracts (swaps) with one or more counterparties to obtain the return on the index. The KIID and PRIIPs KID explicitly state the use of derivatives and swap agreements as the core replication method (synthetic replication). The fund does not invest directly in the underlying securities but relies on total return swaps, exposing investors to counterparty risk. There is no leverage or inverse exposure, and the risk profile is low (risk level 2), but the presence of synthetic replication and counterparty risk classifies the ETF as complex under MiFID II. The factsheet confirms indirect replication via swaps and highlights counterparty risk. No capital protection or structured features are present. The fund invests in a single index constituent (a notional deposit earning SONIA), but the use of swaps and derivatives as an inherent part of the strategy, rather than for risk management, triggers complexity classification. The risk disclosures emphasize counterparty risk and derivative risk, and the fund's replication method is not physical but synthetic. Therefore, despite a low risk rating and no leverage, the synthetic swap-based structure and counterparty exposure make this ETF complex under MiFID II."
}