{
    "fund_name": "Market Access Rogers International Commodity Index UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Commodity futures exposure",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a swap agreement with BNP Paribas S.A., exposing investors to counterparty risk. The underlying index consists of commodity futures contracts, which are inherently complex due to roll costs, contango/backwardation effects, and volatility. The KIID explicitly mentions counterparty risk as a significant factor, and the swap-based structure introduces additional layers of complexity beyond direct physical replication. The risk rating of 6 further supports the classification as complex.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "underlying_assets": "Commodity futures contracts",
    "benchmark_complexity": "High (multi-currency, multi-exchange commodity futures)",
    "liquidity_considerations": "Secondary market liquidity may vary, and the swap structure adds complexity to the redemption process.",
    "regulatory_notes": "The ETF is UCITS-compliant, but the use of swaps and commodity futures triggers MiFID II complexity criteria. The PRIIPs KID and factsheet reinforce the synthetic replication and counterparty risk warnings, which are key indicators of complexity under MiFID II."
}