{
    "type": "ETF",
    "ucits": true,
    "fund_name": "AMUNDI MSCI EUROPE HIGH DIVIDEND FACTOR UCITS ETF - EUR",
    "investment_objective": "Track the performance of MSCI Europe High Dividend Yield Index with minimized tracking error",
    "primary_asset_class": "Equity",
    "geographic_focus": "Europe",
    "replication_method": "synthethic",
    "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 ETF uses an indirect replication methodology via total return swaps (financial derivative instruments) to achieve exposure to the MSCI Europe High Dividend Yield Index. The KIID and PRIIPs KID explicitly state that derivatives are integral to the investment strategy, confirming the use of synthetic replication. The fund is UCITS compliant but exposes investors to counterparty risk inherent in swap agreements. There is no leverage or inverse exposure. The underlying index is a standard equity dividend yield index without complex structured products. The risk profile is medium (4/7), reflecting market and counterparty risks. Costs are straightforward with no performance fees, but swap usage implies derivative costs. The synthetic replication and swap usage are the primary drivers of complexity under MiFID II, as they introduce counterparty risk and reduce transparency compared to physical replication. No capital protection or structured features are present. The PRIIPs KID does not include a comprehension warning but confirms derivative use and counterparty risk disclosures. The monthly factsheet confirms synthetic replication and swap usage, with low tracking error and no leverage. Overall, the presence of funded total return swaps and integral derivative use classifies this ETF as complex under MiFID II despite a moderate risk profile and straightforward underlying assets."
}