{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS MSCI Singapore UCITS ETF",
    "investment_objective": "Passive management aiming to track the MSCI Singapore Index (Net Return) through direct investments in all or substantially all component securities and/or derivatives to gain exposure or efficiencies.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Singapore",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC derivatives (swaps) for efficiency and exposure, counterparty risk, structured notes holdings",
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication (full replication) but also employs derivatives, specifically OTC swaps, to gain exposure where direct replication is impractical or to improve efficiency. The KIID explicitly mentions the use of derivatives and OTC swaps, which introduce counterparty risk mitigated by collateral policies. The fund invests predominantly in equities but also holds structured notes and may engage in securities lending. The PRIIPs KID confirms the use of derivatives is not merely for risk management but as an inherent part of the investment strategy. The risk profile is medium to high (risk category 5 in KIID, 4 in PRIIPs), reflecting volatility and derivative-related risks. The fund is UCITS compliant and does not use leverage or inverse strategies. The presence of OTC derivatives and swap agreements, even if partially physical replication is used, triggers MiFID II complexity classification. No leverage or inverse exposure is present, and derivatives are not solely for hedging but for exposure. The fact sheet confirms physical replication as primary but acknowledges swap usage. No capital protection or structured contingent features are present. Costs are straightforward with no performance fees but include derivative trading costs and collateral management risks. Overall, the use of OTC swaps and counterparty risk exposure, combined with derivative usage beyond risk management, leads to classification as complex under MiFID II despite the fund's straightforward equity index tracking objective and UCITS status."
}