{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers Spain UCITS ETF",
    "investment_objective": "To replicate the performance of the Solactive Spain 40 Index, which tracks 40 major Spanish companies listed on Spanish stock exchanges.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Spain",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF aims to physically replicate the Solactive Spain 40 Index by buying all or a substantial number of the underlying securities. 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. The fund is UCITS compliant, uses direct physical replication, and invests in liquid, transparent Spanish equities. The risk profile is relatively high (category 6 in KIID, 5 in PRIIPs) due to concentration in a single country and equity market volatility, but this does not imply complexity under MiFID II. There is no leverage, inverse exposure, capital protection, or complex structured products involved. Costs are straightforward with a TER of 0.30%, no performance fees, and minimal securities lending revenue. The PRIIPs KID does not include any comprehension warnings or complexity flags. The factsheet confirms direct physical replication and no use of swaps or synthetic structures. Overall, the ETF is a straightforward, physically replicated equity index tracker with minimal derivative use for risk management only, thus classified as non-complex under MiFID II."
}