{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Investment in AAA-rated CLOs",
    "classification": "complex",
    "supporting_data": "The Janus Henderson Tabula USD AAA CLO UCITS ETF invests primarily in AAA-rated collateralized loan obligations (CLOs), which are complex structured credit products. The fund is actively managed and may deviate significantly from its benchmark, the J.P. Morgan CLO Index. The KIID explicitly states that the product 'is not simple and may be difficult to understand,' indicating inherent complexity. There is no mention of synthetic replication, swaps, or leverage; derivatives are only used for hedging interest rate and currency risk, not as a core part of the investment strategy, so derivatives are marked false. The fund invests directly in CLO securities, which are known to be complex and illiquid, with risks including liquidity risk, credit risk, and dependence on CLO managers. The risk rating is 3, which is moderate, but the complexity arises from the nature of the underlying assets rather than leverage or derivative usage. No capital protection or structured features are present. Costs are straightforward with no performance fees or swap fees. The complexity classification is driven primarily by the underlying asset class (CLOs), which are complex structured products that retail investors may find difficult to understand, fulfilling MiFID II criteria for complexity despite the absence of leverage or synthetic replication."
}