{
    "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 UK 100 UCITS ETF aims to replicate the FTSE RAFI UK 100 Net Total Return Index by physically holding, as far as practicable, all the securities in the index 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 is UCITS compliant, uses physical replication, and does not employ leverage or inverse strategies. The risk profile is moderate (risk category 4 in PRIIPs KID, 6 in KIID but this is due to equity market exposure rather than complexity). The fund engages in securities lending, but this is a common practice and does not itself imply complexity. There are no capital protection features or structured product elements. The underlying assets are large-cap UK equities weighted by fundamental factors (sales, cash flow, book value, dividends) rather than market cap, but this fundamental weighting does not constitute complexity under MiFID II. No contingent convertible bonds, complex structured products, or illiquid assets are held. Costs are straightforward with a single ongoing charge and no performance fees or swap 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 is classified as non-complex under MiFID II."
}