{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi STOXX Europe 600 Consumer Discretionary UCITS ETF Acc",
    "investment_objective": "Track the performance of STOXX Europe 600 Industry Consumer Discretionary 30-15 Index with minimized tracking error",
    "primary_asset_class": "Equity",
    "geographic_focus": "Europe (Developed markets in Europe)",
    "replication_method": "synthethic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swaps",
        "Use of financial derivative instruments integral to strategy",
        "Counterparty risk exposure due to swap agreements"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses an indirect replication methodology via total return swaps to achieve exposure to the STOXX Europe 600 Consumer Discretionary Index, explicitly stated as using financial derivative instruments integral to the investment strategy. The KIID and PRIIPs KID both confirm the use of total return swaps and highlight counterparty risk as a material risk. The fund is UCITS compliant but employs synthetic replication rather than physical replication. There is no leverage or inverse exposure. The underlying index is a broad market cap weighted equity index of European consumer discretionary stocks, which is straightforward and liquid. However, the use of total return swaps and derivative instruments as a core part of the investment strategy, along with counterparty risk disclosures, triggers MiFID II complexity classification. The risk profile is medium-high (5/7) in the PRIIPs KID, reflecting market and derivative risks. Costs are straightforward with no performance fees, but swap usage implies derivative costs. No capital protection or structured features are present. The factsheet confirms synthetic replication and swap usage, with no leverage or complex underlying assets beyond equities. Therefore, despite a straightforward underlying index, the synthetic swap-based replication and associated counterparty risk make this ETF complex under MiFID II rules."
}