{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi USD Fed Funds Rate UCITS ETF Acc",
    "investment_objective": "To reflect the performance of the Solactive Fed Funds Effective Rate Total Return index, representing the performance of a cash notional deposit paying the US Federal Funds Effective Rate with daily reinvestment of interest.",
    "primary_asset_class": "Bond (Money Market Instruments)",
    "geographic_focus": "USA",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication via an over-the-counter swap contract (financial derivative instrument) to achieve its investment objective, as explicitly stated in both the KIID and PRIIPs KID. The fund invests in a diversified portfolio of international debt securities and enters into swap agreements to exchange performance against the benchmark index. The replication method is synthetic, confirmed by the factsheet. There is no leverage or inverse exposure. The fund is UCITS compliant. The risk profile is low (category 1 out of 7), but the presence of counterparty risk from the swap counterparty and the use of derivatives as an inherent part of the strategy classify the ETF as complex under MiFID II. The derivatives are not used solely for risk management but are fundamental to the replication strategy. No capital protection or structured features are present. Costs are straightforward with no performance fees, but swap usage implies counterparty risk and complexity. The complexity arises mainly from the synthetic replication via swaps and counterparty exposure, which may not be easily understood by retail investors despite the low risk rating and straightforward underlying index. No leverage or contingent bonds are involved. The PRIIPs KID does not carry a comprehension warning but confirms the swap usage and counterparty risk disclosures. Overall, the synthetic replication and swap counterparty risk are the key drivers of the complex classification."
}