{
    "fund_name": "Xtrackers II GBP Overnight Rate Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure",
        "Interest rate volatility"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the Solactive SONIA Daily Total Return Index, which reflects the performance of a notional deposit earning interest at the SONIA rate. Key complexity indicators include: (1) Swap-based replication (explicitly stated as 'Indirect Replication (Swap)' in the factsheet), (2) Counterparty risk from derivative agreements, (3) Exposure to interest rate volatility, and (4) Potential tracking error (up to 1%) due to derivative usage. While the fund has a low-risk profile (category 2) and no leverage, the reliance on swaps and counterparty risk makes it complex under MiFID II. The PRIIPs KID and factsheet confirm swap usage and counterparty risk, reinforcing the complexity classification.",
    "confidence": 90
}