{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Total Return Swap",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The AMUNDI FTSE EPRA EUROPE REAL ESTATE UCITS ETF uses an indirect replication methodology via a total return swap, a financial derivative instrument, to achieve its investment objective. The KIID and PRIIPs KID explicitly state that derivatives are integral to the Sub-Fund's investment strategy, confirming the use of synthetic replication rather than physical replication. There is clear mention of counterparty risk associated with the swap counterparty, which is a complexity factor under MiFID II. The fund does not employ leverage or inverse exposure, and the risk profile is moderate (risk level 5 out of 7), reflecting market and counterparty risks. The underlying index tracks listed real estate equities and REITs, which are liquid and transparent, but the synthetic swap structure and counterparty exposure introduce complexity. Costs are straightforward with no performance fees, but swap-related derivative costs are implicit. No capital protection or structured features are present. The PRIIPs KID does not include a comprehension warning but confirms the medium-high risk rating and the integral use of derivatives. Therefore, despite the absence of leverage or complex underlying assets like contingent bonds, the synthetic replication via total return swaps and associated counterparty risk mandate classification as complex under MiFID II."
}