{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "CLO Debt Securities, Use of derivatives for risk management, Actively managed, No benchmark tracking",
    "classification": "complex",
    "supporting_data": "The Invesco USD AAA CLO UCITS ETF is a UCITS-compliant, actively managed ETF that primarily invests in AAA-rated tranches of US Dollar denominated floating rate debt securities issued by collateralised loan obligations (CLOs). CLOs are structured products that pool loans and bonds, and their tranches have different risk/return profiles based on seniority. The Fund may use derivative instruments for managing risk, reducing costs, generating additional capital or income, and for currency hedging. The Fund is not constrained by a benchmark and does not seek to track an index. The KID includes a comprehension alert ('You are about to purchase a product that is not simple and may be difficult to understand'), which is a regulatory requirement for complex products under MiFID II. The intended investor is professional or institutional, not retail, and the Company does not permit secondary market offering to retail investors. The Fundu2019s structure, use of derivatives, and exposure to CLOsu2014a type of structured finance product with embedded credit risk transfer mechanismsu2014introduce complexity that is not typical of plain-vanilla UCITS ETFs. Under MiFID II, while UCITS are generally presumed non-complex, this presumption is overturned if the productu2019s structure, risks, or payoff are difficult for a retail investor with basic knowledge to understand. The use of derivatives (even for risk management) and the holding of complex, structured debt securities (CLOs) are factors that regulators and industry guidance identify as contributing to complexity, especially when the productu2019s performance and risks are not straightforward or easily understood by the average retail investor. The Fundu2019s KID risk indicator is low (2/7), but this reflects market risk, not structural complexity. The structural complexity arises from the CLO exposure and derivative use, which are not typical of non-complex UCITS ETFs that track transparent, liquid indices using physical replication. Therefore, despite being a UCITS ETF, the Fundu2019s investment strategy and holdings make it complex under MiFID II Article 57 criteria."
}