{
    "type": "ETF",
    "ucits": true,
    "fund_name": "VanEck Multi-Asset Growth Allocation UCITS ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The VanEck Multi-Asset Growth Allocation UCITS ETF is a passively managed, UCITS-compliant ETF that physically replicates a composite multi-asset index by direct investment in shares and bonds. The replication method is optimized physical sampling, with no mention of synthetic replication or use of swaps or derivatives as part of the investment strategy. The fund holds approximately 239 positions, investing directly in liquid equity and bond securities, including investment grade corporate and sovereign bonds. There is no leverage, inverse exposure, or capital protection features. The risk profile is moderate (risk level 5 in KIID, 3 in PRIIPs KID), consistent with a diversified multi-asset portfolio. Costs are straightforward with a single ongoing charge of 0.32%, no performance fees, and no swap or derivative fees. The PRIIPs KID confirms no complexity warnings or comprehension warnings. The monthly factsheet confirms physical replication and no use of derivatives or swaps. The underlying indices are standard equity and bond indices with ESG considerations but no complex structured products or contingent bonds. No counterparty risk or derivative counterparty risk disclosures are present. Overall, the fund exhibits none of the MiFID II complexity triggers such as synthetic replication, leverage, complex underlying assets, or capital protection mechanisms. Therefore, it is classified as non-complex."
}