{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Invesco FTSE RAFI Europe UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Invesco FTSE RAFI Europe UCITS ETF aims to replicate the FTSE RAFI Europe Index (Net Total Return) by physically holding all or substantially all of the underlying shares in their respective weightings. The KIID and PRIIPs KID documents explicitly state that the Fund uses physical replication and does not employ synthetic replication or swap agreements. There is no mention of funded or unfunded swaps, total return swaps, or counterparty exposure related to derivatives. The Fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage, inverse or amplified exposure, and no capital protection or structured features. The risk profile is medium (risk category 4 in PRIIPs KID, 6 in KIID but this is consistent with equity market risk rather than complexity). The Fund invests directly in liquid, transparent equity securities of large and mid-cap European companies selected by fundamental factors, not complex structured products or contingent convertible bonds. The ongoing charges are straightforward with no performance fees or swap fees. Securities lending is disclosed but is a common practice and does not add complexity. The monthly factsheet confirms physical replication, no use of swaps or synthetic structures, and a straightforward index tracking approach. There is no PRIIPs comprehension warning or other complexity flags. Therefore, the Fund is classified as non-complex under MiFID II."
}