{
    "fund_name": "UBS (Irl) Fund Solutions plc - UBS 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 swaps",
        "Counterparty risk exposure",
        "Commodity index complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps with UBS as counterparty, which introduces counterparty risk. The underlying index (UBS CMCI Ex-Agriculture Ex-Livestock Capped Index) is a commodity index with multiple maturities and components, adding complexity. The KIID explicitly mentions 'financial derivative instruments' and 'counterparty risk' as material risks. The PRIIPs KID and fact sheet confirm the use of a fully funded total return swap, which while common in synthetic ETFs, still triggers MiFID II complexity due to the derivative exposure and counterparty risk. The risk profile is rated 6/7, indicating high complexity. The fact that the fund is UCITS-compliant does not override the complexity classification under MiFID II when derivatives and counterparty risk are involved.",
    "confidence": 90
}