{
    "name": "Invesco S&P SmallCap 600 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly states that the Fund will use swaps to exchange the performance of a basket of equities for the performance of the S&P SmallCap 600 Index. This synthetic replication method, combined with the reliance on counterparties, makes the product complex under MiFID II. Additionally, the risk category is 7, indicating higher risk, and the document highlights risks associated with synthetic ETFs and counterparty exposure.",
    "confidence": 90,
    "risk_level": 7,
    "counterparty_risk": true,
    "benchmark_complexity": "low",
    "liquidity_risk": "moderate",
    "additional_notes": "While the ETF tracks a straightforward equity index, the use of synthetic replication via swaps and the associated counterparty risks are the primary drivers of its classification as complex. The PRIIPs KID and factsheet reinforce the synthetic nature and the risks involved, which are not typically present in physically replicated ETFs."
}