{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreements",
        "Counterparty risk exposure",
        "Use of derivatives for index exposure"
    ],
    "classification": "complex",
    "supporting_data": "The fund is a UCITS ETF that tracks the Solactive \u20acSTR +8.5 Daily Total Return Index using an indirect replication method via swap agreements with one or more counterparties. The KIID and factsheet explicitly state the use of derivatives and swaps to achieve the investment objective, with counterparty risk clearly disclosed. The replication is synthetic, not physical, and the fund does not invest directly in the underlying index components. There is no leverage or inverse exposure, and the risk profile is low (category 1), but the presence of swap-based synthetic replication and counterparty risk triggers MiFID II complexity classification. The PRIIPs KID confirms the use of derivatives and counterparty risk, and the factsheet confirms indirect replication via swaps. No capital protection or structured features are present, and costs are straightforward with no performance fees. Despite the low risk rating, the synthetic swap structure and counterparty exposure make the ETF complex under MiFID II rules."
}