{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers S&P 500 UCITS ETF aims to replicate the S&P 500 Index by direct physical replication, purchasing all or a substantial number of the underlying securities. The fund uses derivatives only for currency hedging purposes to reduce exchange rate fluctuations between the USD-denominated assets and the EUR share class currency, not as an inherent part of the investment strategy. There is no mention of synthetic replication, swap agreements, or total return swaps. The fund does not employ leverage or inverse exposure. The underlying assets are large-cap US equities, which are liquid and transparent. There are no capital protection or structured features. The risk profile is medium-high (risk level 5 out of 7), consistent with equity market exposure, but this does not imply complexity under MiFID II. Costs are straightforward with a simple ongoing charge of 0.20% and no performance fees or swap fees. Securities lending is minimal and revenue sharing is disclosed but 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 for index replication. Therefore, the fund is classified as non-complex under MiFID II."
}