{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi US Treasury Bond 1-3Y UCITS ETF Dist",
    "investment_objective": "Track Bloomberg Barclays US Treasury 1-3 Year Index via direct replication or sampling",
    "primary_asset_class": "Bond",
    "geographic_focus": "United States",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC swaps for securities lending and optimization, Counterparty risk exposure",
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS fund physically replicating the Bloomberg Barclays US Treasury 1-3 Year Index primarily through direct purchase of underlying US Treasury bonds with maturities between 1 and 3 years. The fund uses a sampling replication strategy to optimize tracking. The risk disclosures and factsheet reveal the use of OTC swaps with counterparties such as Morgan Stanley Bank AG and Societe Generale, primarily related to securities lending programs and replication optimization. Although the derivatives risk section states the fund invests in financial derivatives, the use is limited and not inherent to the investment strategy but for operational purposes. The fund does not employ leverage or inverse strategies, and the risk profile is low (SRRI 2/7). However, the presence of OTC swaps and counterparty risk exposure, even if limited to 10% of assets, triggers MiFID II complexity classification. There are no capital protection features or structured products involved. Costs are straightforward with no performance fees and low ongoing charges (0.06%). The PRIIPs KID does not include a comprehension warning, and the risk indicator is low, but the swap usage and counterparty risk elevate the complexity under MiFID II rules. The underlying assets are liquid US Treasury bonds, and the replication is physical, but the swap usage for securities lending and replication optimization is a complexity factor. Therefore, despite a low risk profile and simple underlying assets, the fund is classified as complex due to swap usage and counterparty risk exposure."
}