{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "RMBS exposure with credit and liquidity risks",
    "classification": "non-complex",
    "supporting_data": "The Regan Total Return Income UCITS ETF primarily invests in a portfolio of residential mortgage-backed securities (RMBS), focusing on Agency and Non-Agency MBS, with at least 80% allocation to RMBS. The fund employs an active management approach selecting bonds based on bottom-up credit analysis. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used for replication or leverage. The replication method is physical, investing directly in fixed income securities. No leverage or inverse exposure is indicated. The risk profile is moderate (category 3), reflecting credit, liquidity, and interest rate risks inherent in RMBS, but no complexity flags such as capital protection, structured features, or contingent bonds are present. Charges are straightforward with no performance fees or swap fees. The fund is UCITS compliant. The absence of derivative usage for investment strategy and no leverage or swap usage leads to a non-complex classification under MiFID II. Although RMBS can be complex credit instruments, the fund\u2019s direct physical investment and lack of synthetic or leveraged structures mean it does not meet the complexity threshold. No PRIIPs KID or factsheet information was provided to alter this assessment."
}