{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Derivatives for strategy"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, which is presumed non-complex and normally uses a physical replication strategy, its classification is determined to be 'complex'. The decisive factor is the explicit statement in the KIID that the Fund 'may also (or alternatively) invest in financial derivative instruments (FDIs) which relate to the Index or constituents of the Index.' The list of permitted FDIs includes 'swaps (including equity swaps and swaps on the Index)'. Under the provided MiFID II assessment rules, 'If any element of... any Swap usage is identified then the 'classification' must be 'complex'.' The use of swaps is central to the complexity determination because it introduces risks, such as counterparty and collateral risk, which are not easily understood by the average retail investor. The language '(or alternatively)' suggests that derivatives are not limited to Efficient Portfolio Management (EPM) but can be used as a core part of the strategy to achieve the investment objective, which is a key trigger for a complex classification. This potential use of complex instruments overrides the non-complex presumption of a physically-replicating UCITS ETF.",
        "final_assessment": "Complex"
    }
}