{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Portfolio Income UCITS ETF is a UCITS-compliant, actively managed ETF domiciled in Ireland. The fund invests primarily in other ETFs linked to equities, fixed income, and commodities, with direct investments in transferable securities and money market instruments as well. The portfolio methodology is explicitly stated as 'Direct Replication (physically)' in the factsheet, indicating no synthetic replication or use of swaps. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments as part of the investment strategy. The fund does not employ leverage or inverse exposure, nor does it have capital protection or structured product features. The risk profile is moderate (risk level 4 out of 7 in the KIID, and 3 out of 7 in the PRIIPs KID), consistent with a balanced multi-asset portfolio. Counterparty risk is disclosed only in relation to potential derivative use by underlying ETFs, but the fund itself does not engage in derivative strategies inherently. Costs are straightforward with a single ongoing charge of 0.65%, no performance fees, and minimal securities lending revenue. The PRIIPs KID does not include any comprehension warnings or complexity flags. The fund's underlying assets are liquid ETFs and transferable securities, with no indication of complex structured products or contingent convertible bonds. Therefore, under MiFID II criteria, the fund is classified as non-complex due to physical replication, absence of leverage, swaps, or complex underlying assets, and a clear, linear investment strategy."
}