{
    "fund_name": "AMUNDI GLOBAL INFRASTRUCTURE - UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure from swap agreements",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which introduces counterparty risk and complexity beyond direct physical replication. While the underlying index (Solactive Global Infrastructure Low Earnings Volatility Index) appears straightforward (equity-focused, global infrastructure companies), the use of derivatives for replication triggers MiFID II complexity classification. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and references counterparty risk, which are key complexity indicators. The PRIIPs KID and factsheet confirm the synthetic replication method, reinforcing the complexity determination. The fund's risk profile (SRRI 3) is moderate, but the derivative-based structure makes it unsuitable for retail investors without specialist knowledge.",
    "confidence": 90,
    "counter_argument": "One could argue that the underlying index is simple (equity-focused, low volatility infrastructure stocks) and the swap usage is standard for synthetic replication. However, MiFID II explicitly considers derivative-based replication as a complexity factor, regardless of the underlying asset class's simplicity. The presence of counterparty risk and the indirect replication method override the simplicity of the index.",
    "risk_level_alignment": "The fund's SRRI 3 (moderate risk) aligns with the underlying equity exposure, but the synthetic structure introduces additional risks (counterparty, tracking error) that may not be fully appreciated by retail investors, reinforcing the 'complex' classification."
}