{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "leverage": false,
        "inverse": false,
        "complex_factors": [
            "Swaps",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF uses a swap-based replication method, specifically referencing a total return swap (TRS derivative instrument). According to MiFID II and ESMA guidelines, the use of derivatives integral to achieving the investment objective, such as swaps for index replication, introduces risks like counterparty risk and collateral risk, which are generally considered complex for retail investors. The KIID explicitly mentions 'Counterparty risk' as a particular risk for the UCITS. While UCITS ETFs are generally presumed non-complex, the reliance on synthetic replication via swaps shifts the classification to complex due to the inherent opacity and associated risks that are not easily understood by an average retail investor. The documentation also notes the potential for tracking error, a common characteristic of synthetic replication."
    }
}