{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreements",
        "Counterparty risk exposure",
        "Complex index methodology (Shiller Barclays CAPE\u00ae US Sector Value Index)"
    ],
    "classification": "complex",
    "supporting_data": "The fund uses synthetic replication primarily through multiple swap agreements with first-class financial institutions to track the Shiller Barclays CAPE\u00ae US Sector Value Net TR Index. The KIID and PRIIPs KID explicitly mention the use of swaps and associated counterparty risk, which is a key complexity indicator under MiFID II. The replication method is synthetic, not physical, and the fund may switch partially or totally between synthetic and physical replication, but synthetic is the primary method. There is no leverage or inverse exposure, and derivatives are used as an inherent part of the strategy, not merely for risk management, so 'derivatives' is marked false per instructions. The underlying index is complex, involving dynamic sector selection based on CAPE ratios and momentum, which adds to the complexity. The risk profile is medium-high (risk class 5-6), reflecting volatility and counterparty risk. Costs include a TER of 0.65% with no performance fees, and no leverage or capital protection features are present. The PRIIPs KID confirms the complexity with a comprehension warning implied by the detailed risk disclosures and the recommended 5-year holding period. Overall, the presence of synthetic replication via swaps and counterparty risk drives the classification as complex under MiFID II, despite the absence of leverage or capital protection features."
}