{
    "type": "ETF",
    "ucits": true,
    "fund_name": "JPM Emerging Markets Local Currency Bond Active UCITS ETF - USD (acc)",
    "investment_objective": "Achieve long-term return in excess of J.P. Morgan GBI-EM Global Diversified (Total Return Gross) by actively investing primarily in emerging market local currency debt securities.",
    "primary_asset_class": "Bond",
    "geographic_focus": "Emerging Markets",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF is an actively managed UCITS ETF investing primarily in emerging market local currency government and corporate bonds. The KIID and PRIIPs KID indicate the use of financial derivative instruments only for gaining exposure or efficient portfolio management, not as an inherent part of the investment strategy, thus derivatives are considered false for complexity purposes. There is no mention of synthetic replication, swap agreements, or funded/unfunded swaps. The replication is physical, with direct holdings in bonds and notes. There is no leverage or inverse exposure. The risk profile is moderate (category 5 in KIID, 3 in PRIIPs KID), reflecting the underlying emerging market bond risks, but not complexity from structure. The fund holds some contingent convertible bonds (CoCos) as underlying assets, which are complex instruments, but these are part of the underlying bond portfolio rather than the ETF structure itself. The costs are straightforward with no performance fees or swap fees, and ongoing charges are typical for bond ETFs (0.45%). The PRIIPs KID does not carry a comprehension warning. The factsheet confirms direct holdings in bonds, no synthetic replication, and no leverage. Therefore, under MiFID II, the ETF is classified as non-complex because it uses physical replication, has no leverage or synthetic swap structures, and derivatives are used only for risk management or efficient portfolio management, not as a core strategy element. The presence of CoCos in the underlying portfolio does not trigger complexity classification for the ETF itself, as the ETF structure is straightforward and transparent."
}