{
    "type": "ETF",
    "ucits": true,
    "fund_name": "First Trust Germany AlphaDEX\u00ae UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS-compliant ETF domiciled in Ireland, tracking the NASDAQ AlphaDEX\u00ae Germany Index using a physical replication method with full or representative sampling of underlying equity securities. The KIID and PRIIPs KID documents confirm the fund invests primarily in equity securities included in the index, with no mention of synthetic replication, swap agreements, or derivative instruments as part of the investment strategy. The fact sheet explicitly states the replication method is physical and full replication. There is no leverage, inverse exposure, or capital protection features. The risk indicator is moderate (5 out of 7), consistent with equity market risk but not indicative of complexity due to derivatives or leverage. Costs are straightforward with no performance fees or swap fees. The fund uses a semi-annual rebalance of the index, which is an enhanced index using fundamental factors, but this does not introduce complexity under MiFID II. No counterparty risk or derivative counterparty risk disclosures are present. The fund\u2019s holdings are liquid, transparent equities with no complex structured products or contingent bonds. The PRIIPs KID does not include any comprehension warnings or complexity flags. Therefore, the fund is classified as non-complex under MiFID II."
}