{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": true,
    "inverse": false,
    "complex_factors": [
        "Leverage",
        "Synthetic replication via swaps",
        "Counterparty risk",
        "Leveraged index exposure"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers LevDAX Daily Swap UCITS ETF uses synthetic replication through swap agreements to achieve its investment objective, explicitly stated as entering into financial contracts (derivatives) with one or more swap counterparties. The fund targets a leveraged exposure of 2x the DAX Index on a daily basis, which is a clear leverage indicator. The fund does not invest directly in the underlying securities but swaps most subscription proceeds for the return on the index, confirming synthetic replication. The risk disclosures highlight significant counterparty risk and derivative risk, with a high risk rating of 6 out of 7 in the PRIIPs KID. The fund is designed for short-term investors with advanced knowledge, indicating complexity. The factsheet confirms indirect replication via swaps and highlights counterparty risk explicitly. There are no capital protection features, but the leverage and swap usage, combined with the complexity of the leveraged index, drive the classification. The fund\u2019s risk profile and the use of derivatives for achieving the investment objective (not merely for risk management) further support the complex classification under MiFID II."
}