{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI USA ESG UCITS ETF",
    "investment_objective": "Track the performance of the MSCI USA Low Carbon SRI Selection Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "USA",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF aims to physically replicate the MSCI USA Low Carbon SRI Selection Index by buying all or a substantial number of the underlying securities. The factsheet explicitly states 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, or total return swaps. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage or inverse exposure. The underlying assets are large and mid-cap US equities with ESG and low carbon criteria, which are liquid and transparent. No capital protection or structured features are present. The risk profile is medium-high (category 5 out of 7), reflecting market risk rather than structural complexity. Costs are straightforward with a simple ongoing charge of 0.15% and no performance fees or swap fees. The PRIIPs KID does not include any comprehension warnings or complexity flags. The fund is UCITS compliant and regulated by the Central Bank of Ireland. Overall, the fund exhibits a clear, linear relationship to the underlying index performance with minimal derivative use and no leverage, making it non-complex under MiFID II criteria."
}