{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps"
        ],
        "classification": "complex",
        "supporting_data": "The ETF aims to achieve its investment objective by investing in financial derivative instruments (FDIs), specifically entering into unfunded total return swaps to replicate the MSCI USA Index. While physical replication is mentioned as a fallback, the primary method involves synthetic replication through swaps. MiFID II and ESMA guidelines clearly classify the use of derivatives, particularly swaps, for replication purposes as a factor that can lead to a complex classification due to the associated counterparty and collateral risks, which are not easily understood by retail investors. The KID explicitly states that derivatives may be highly sensitive and increase losses/gains. The risk indicator is rated six, and counterparty risk is specifically highlighted as a particular risk not adequately captured by the indicator. The use of swaps as the core replication strategy makes this ETF complex under MiFID II, as it introduces risks and a structure that are difficult for a retail investor with basic knowledge to fully comprehend, even though the underlying index itself is a standard equity index."
    }
}