{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swaps",
        "Counterparty risk exposure",
        "Use of derivatives integral to strategy"
    ],
    "classification": "complex",
    "supporting_data": "The AMUNDI NASDAQ-100 UCITS ETF uses an indirect replication method via total return swaps, explicitly described as financial derivative instruments integral to the investment strategy. The KIID and PRIIPs documents both confirm the use of total return swaps, indicating synthetic replication rather than physical replication. There is explicit mention of counterparty risk associated with these swaps. No leverage or inverse exposure is present. The underlying index is a standard equity index (NASDAQ-100) composed of liquid, large-cap US and non-US stocks, so underlying asset complexity is low. The risk profile is medium-high (5/7), reflecting market risk and counterparty risk from swap usage. Costs are straightforward with no performance fees, but swap-related derivative costs are implicit. Given the synthetic replication and swap usage, the ETF is classified as complex under MiFID II, despite the absence of leverage or complex underlying assets. The complexity arises primarily from the use of derivatives (total return swaps) and associated counterparty risk, which may reduce transparency and increase investor understanding difficulty."
}