{
    "name": "Xtrackers S&P 500 Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the S&P 500 Index, which introduces counterparty risk and derivative exposure. The KIID explicitly mentions 'swap index' and 'derivative counterparty risk,' indicating reliance on unfunded swaps. While the fund does not employ leverage or inverse strategies, the synthetic replication method and associated counterparty risks are key complexity indicators under MiFID II. The risk level is classified as category 5, reflecting higher volatility and counterparty risk. The fund's documentation highlights potential tracking error due to swap adjustments and counterparty insolvency risks, which are not present in physically replicated ETFs.",
    "confidence": 90,
    "counterparty_risk": true,
    "tracking_error_risk": true,
    "liquidity_risk": false,
    "risk_level": 5,
    "additional_notes": "Although the ETF does not use leverage or target complex indices, the synthetic replication via swaps and the associated counterparty risks are sufficient to classify it as complex under MiFID II. The PRIIPs KID and factsheet reinforce the swap-based structure and counterparty dependencies, which are not easily understood by retail investors without specialized knowledge."
}