{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "Active management with quantitative factor exposure; use of securities lending; minor derivative use for risk management only",
    "classification": "non-complex",
    "supporting_data": "The HSBC PLUS USA Equity Quant Active UCITS ETF primarily invests physically in US equities and equity-like securities such as ADRs and GDRs, with at least 90% of net assets in these instruments. The fund is actively managed with a quantitative factor-based approach focusing on value, quality, momentum, low risk, and size factors. The KIID and monthly factsheet explicitly state that derivatives may be used only for efficient portfolio management purposes (risk and cost management or generating additional capital/income), not as an inherent part of the investment strategy. There is no mention of synthetic replication, swap agreements, total return swaps, or counterparty exposure related to derivatives. The fund does not employ leverage or inverse strategies, and the risk level is 6, reflecting market volatility rather than structural complexity. Securities lending is used but capped at 30% (typically below 25%), which is common and not a complexity driver under MiFID II. The fund is UCITS compliant, uses physical replication, and invests directly in liquid, transparent securities. No capital protection or structured features are present. Fees are straightforward with a low ongoing charge and no performance fees. No PRIIPs KID comprehension warnings or complexity flags are noted. Therefore, despite active management and minor derivative use for risk management, the fund does not meet MiFID II criteria for a complex financial instrument."
}