{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco FTSE RAFI US 1000 UCITS ETF is a physically replicated, passively managed ETF that aims to track the FTSE RAFI US 1000 Index by holding all or substantially all of the underlying shares in their respective weightings. There is no mention of synthetic replication, swap agreements, or derivative instruments used as part of the investment strategy, only that derivatives may be used for risk management purposes, which does not trigger complexity under MiFID II. The fund does not employ leverage or inverse exposure. The underlying assets are large-cap US equities, which are liquid and transparent. The risk profile is medium-high (risk category 5-6), consistent with equity market exposure, but there are no capital protection or structured features. Securities lending is used, but this is common and disclosed, with no complex fee structures or performance fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The monthly factsheet confirms physical replication and no use of swaps or leverage. Therefore, the ETF does not meet the MiFID II criteria for classification as a complex financial instrument."
}