{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers USD High Yield Corporate Bond UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "inverse": false,
    "derivatives": false,
    "swaps": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant fund physically replicating the Bloomberg US High Yield Very Liquid Index ex 144A by direct purchase of underlying bonds. The factsheet explicitly states 'Direct Replication (physically)' and no mention of synthetic replication or swap usage is found in the KIID, PRIIPs KID, or factsheet. The fund may use derivatives only for risk management purposes, which does not trigger complexity classification. There is no leverage, inverse exposure, or capital protection features. The underlying assets are high yield corporate bonds, which are non-investment grade and carry credit risk, but are straightforward fixed income securities without embedded contingent features. The risk profile is medium to medium-low (risk category 3-5 depending on document), consistent with bond market risk rather than complexity. No significant counterparty risk or derivative counterparty risk disclosures are present. Costs are simple with a TER of 0.20%, no performance fees, and no swap or derivative fees. The index tracked is a liquid, transparent bond index without complex structured products or contingent bonds. No complexity warnings or comprehension warnings appear in the PRIIPs KID. Therefore, the fund does not meet MiFID II criteria for a complex financial instrument."
}