{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Lux) Fund Solutions - MSCI USA Socially Responsible UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant, passively managed fund that physically replicates the MSCI USA SRI Low Carbon Select 5% Issuer Capped Total Return Net Index. The factsheet explicitly states 'Physical (Full replicated)' replication methodology, with no mention of synthetic replication or swap agreements. The KIID and PRIIPs KID confirm that derivatives may be used only for risk management or efficiency purposes, not as an inherent part of the investment strategy, thus derivatives exposure is minimal and not complexity-driving. There is no leverage, inverse or amplified exposure language. The underlying assets are equities of US companies with ESG focus, which are liquid and transparent. No capital protection or structured features are present. The risk profile is medium (4 out of 7 in PRIIPs KID, 6 in KIID but driven by equity volatility, not complexity). Costs are straightforward with a TER of 0.22%, no performance fees, no swap or derivative fees. The PRIIPs KID includes a comprehension warning stating the product 'is not simple and may be difficult to understand,' but this is standard language for ETFs tracking ESG indices and does not reflect structural complexity such as swaps or leverage. The fund does not engage in securities lending. Tracking error is very low (~0.09%), indicating close index replication. No complex underlying assets like contingent convertible bonds or CLOs are held. Overall, the fund exhibits none of the MiFID II complexity triggers such as synthetic replication, leverage, complex derivatives, or capital protection mechanisms. Therefore, it is classified as non-complex."
}