{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi Global Equity Quality Income UCITS ETF Acc",
    "investment_objective": "Track the upward and downward unlevered performance of the SG Global Quality Income NTR Index, a net total return index of high quality global equities with high dividend yield",
    "primary_asset_class": "equity",
    "geographic_focus": "global/international developed markets",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via OTC swap",
        "Counterparty risk exposure",
        "Use of financial derivative instruments (FDI) for replication",
        "Currency hedging strategy"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication through an over-the-counter swap contract with counterparties such as Morgan Stanley Bank AG and Societe Generale, which is a funded swap structure as per UCITS guidelines with counterparty exposure capped at 10%. The fund invests in a diversified portfolio of international equities and exchanges performance via the swap to track the SG Global Quality Income NTR Index. The use of OTC swaps and derivative instruments for replication inherently introduces counterparty risk and complexity. The risk disclosures highlight counterparty risk, derivative-related risks (including leverage risk, valuation risk, liquidity risk), and operational risk. The fund is UCITS compliant but uses synthetic replication rather than physical replication. There is no leverage or inverse exposure, and derivatives are used as an inherent part of the replication strategy, not merely for risk management. The risk rating is medium (4/7), reflecting market and counterparty risks. The benchmark index is a complex quality dividend index with 75 holdings globally, which adds to the complexity. Costs are straightforward with no performance fees, but the presence of swap fees and derivative costs is implied. The PRIIPs KID does not carry a specific comprehension warning but confirms the use of OTC swaps and counterparty risk. Overall, the synthetic replication via swaps and associated counterparty risk are the main drivers of the classification as complex under MiFID II."
}