{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Counterparty risk",
            "Collateral risk",
            "Indirect replication"
        ],
        "classification": "complex",
        "supporting_data": "The UCITS ETF aims to replicate an index using indirect replication, specifically through over-the-counter total return swaps. The use of OTC total return swaps introduces counterparty risk and collateral risk, which are not easily understood by retail investors. While the ETF tracks an ESG-focused index, the underlying replication mechanism itself is a key driver of complexity. Although the document does not explicitly mention leverage or embedded derivatives in the traditional sense, the reliance on swaps for replication is sufficient to classify it as complex under MiFID II rules, as highlighted in the provided guidance, particularly the CESR advice and ESMA interpretations where derivative-based replication methods are generally considered complex due to counterparty and collateral risks."
    }
}