{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS MSCI Pacific ex Japan UCITS ETF",
    "investment_objective": "Passive management aiming to replicate the MSCI Pacific ex Japan Index (Net Return) through direct investments in all or substantially all component securities and/or derivatives to gain exposure or generate efficiencies.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Pacific region excluding Japan",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC derivatives with counterparty risk, securities lending, derivative usage for efficiency, collateral policy mitigating counterparty risk",
    "classification": "complex",
    "supporting_data": "The fund primarily uses physical replication but also employs derivatives, including OTC derivatives, to gain exposure or improve efficiency. The KIID and PRIIPs KID explicitly mention the use of derivatives where direct replication is not practicable and note counterparty risk associated with OTC derivatives, mitigated by collateral policies. The fund may engage in securities lending. The PRIIPs KID states the product is 'not simple and may be difficult to understand,' which is a complexity indicator under MiFID II. The risk profile is medium to high (risk category 5 in KIID, 4 in PRIIPs KID), reflecting equity volatility and derivative usage. There is no leverage or inverse exposure. The derivatives are used as an inherent part of the strategy to replicate the index efficiently, not solely for risk management, so derivatives are marked true. The fund is UCITS compliant. The fact sheet confirms physical full replication as the primary method but acknowledges derivative use for efficiency. No capital protection or structured features are present. Costs are straightforward with no performance fees, and ongoing charges are low. Overall, the presence of OTC derivatives with counterparty risk and the use of derivatives as part of the replication strategy classify this ETF as complex under MiFID II despite its physical replication base and moderate risk profile.",
    "risk_level_assessment": "The fund's risk category is 5 (KIID) and 4 (PRIIPs KID), indicating medium to medium-high risk mainly due to equity market volatility and derivative usage. The complexity arises from the use of OTC derivatives and counterparty risk rather than leverage or structured products. This aligns with the MiFID II complexity classification, as the fund's derivative usage and counterparty exposure require a higher level of investor understanding."
}