{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty Risk",
            "Collateral Risk",
            "Derivatives Integral to Strategy"
        ],
        "classification": "complex",
        "supporting_data": "The ETF uses financial derivative instruments (FDIs), specifically total return 'unfunded' OTC swaps, as an integral part of its strategy to replicate the Solactive Disruptive Materials v2 Index. This reliance on swaps introduces risks such as counterparty risk and collateral risk, which are generally considered complex for retail investors to understand. While the ETF is UCITS compliant, the use of synthetic replication through swaps makes it complex under MiFID II guidelines, as these derivatives are central to achieving its investment objective. The KIID explicitly states the use of 'total return u201cunfundedu201d OTC swaps and exchange-traded equity futures for investment purposes.' This direct mention of swaps for investment purposes, rather than solely for efficient portfolio management, classifies it as complex. Additionally, the ETF's high risk category (7 out of 7) and the inherent volatility of the underlying disruptive materials companies and their stock prices, while not solely determinative of complexity, contribute to the overall risk profile that requires a complex classification due to the underlying mechanisms. According to MiFID II and CESR guidelines, the use of derivatives integral to the investment objective, such as total return swaps for index replication, automatically leads to a complex classification because these instruments and their associated risks (counterparty, collateral) are not easily understood by retail investors."
    }
}