{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI USA Consumer Discretionary UCITS ETF",
    "investment_objective": "To track the performance, before fees and expenses, of the MSCI USA Consumer Discretionary 20/35 Custom Index by buying all or a substantial number of the securities in the index.",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States of America",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The ETF uses direct physical replication by purchasing a substantial number of the underlying securities in the MSCI USA Consumer Discretionary 20/35 Custom Index. 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 in the consumer discretionary sector, which are liquid and transparent. The risk profile is medium-high (5/7) due to sector concentration and market volatility, not due to structural complexity. Costs are straightforward with a low ongoing charge of 0.12% and no performance fees or swap fees. Securities lending is minimal and revenue sharing does not increase costs. The PRIIPs KID does not include any comprehension warnings or complexity flags. The factsheet confirms physical replication and no use of swaps or synthetic structures. Overall, the ETF exhibits a clear, linear relationship to the underlying index performance with minimal derivative use for risk management, no leverage, and no complex underlying assets or capital protection features. Therefore, it is classified as non-complex under MiFID II."
}