{
    "fund_name": "UBS (Irl) Fund Solutions plc - CMCI Ex-Agriculture SF UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using derivatives",
        "Swap agreements with counterparty risk",
        "Complex commodity index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps with UBS as counterparty, which introduces counterparty risk. The underlying index (UBS CMCI Ex-Agriculture Ex-Livestock Capped Index) is a complex commodity index with multiple maturities and sectors. While the ETF itself is not leveraged, the use of derivatives for replication and the complexity of the tracked index make this a complex product under MiFID II. The KIID and PRIIPs documents highlight counterparty risk and the need for investors to understand commodity market risks, further supporting the complex classification.",
    "confidence": 90
}