{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Alpha UCITS SICAV - Fair Oaks AAA CLO Fund UCITS ETF EUR Dist. Share Class",
    "investment_objective": "To seek attractive risk-adjusted returns primarily by investing in and managing a portfolio of European and US AAA-rated collateralised loan obligations (CLOs) on a long-only and liquid basis.",
    "primary_asset_class": "Fixed Income (Collateralised Loan Obligations - CLOs)",
    "geographic_focus": "Europe and US (no emerging markets)",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Investment in complex underlying assets (AAA-rated CLOs)",
    "classification": "complex",
    "supporting_data": "The ETF invests up to 100% in AAA-rated CLO debt securities, which are complex structured credit products with layered tranches and credit risk absorption features. The fund is actively managed with no benchmark and uses physical holdings of CLO notes rather than synthetic replication or swaps. Derivatives are only used for currency hedging, not for investment exposure. There is no leverage or inverse exposure. The risk profile is medium/high (risk level 4) reflecting the complexity and credit risk of CLOs. The PRIIPs KID classifies the product as low risk (2/7), but this likely reflects volatility rather than complexity. CLOs are inherently complex due to their structured nature, credit risk, liquidity risk, and valuation challenges. The fund is UCITS compliant but holds complex underlying assets that are not straightforward fixed income securities. There is no mention of synthetic replication, swaps, or leverage. The fund does not have capital protection or structured payoff features. The complexity arises primarily from the nature of the underlying CLO assets, which are structured credit products with contingent cash flows and credit risk layering, making them difficult for retail investors to understand fully. The fund is restricted from sale to mass retail investors and is intended for informed or institutional investors, further indicating complexity. Fees are straightforward with a TER of 0.35%, no performance fees, and no swap or derivative fees. The fund uses physical replication of CLO notes, not derivatives for exposure. The monthly factsheet confirms no use of swaps or synthetic replication. The complexity classification under MiFID II is driven by the underlying asset complexity (CLOs), not by leverage or derivatives usage."
}