{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "complex_factors": "Use of derivatives (swaps) to replicate index performance introduces counterparty risk. The active management strategy and investment in various sectors including emerging markets adds complexity.",
        "classification": "complex",
        "supporting_data": "The JPM Global Aggregate Bond Active UCITS ETF uses financial derivative instruments for investment purposes, which according to MiFID II, can trigger a complex classification. The fact that the fund actively manages its portfolio and the usage of swaps, adds more factors for complexity classification. The KID document explicitly states the use of financial derivative instruments for investment. Also, the fund invests in various sectors including emerging markets, which is not necessarily a factor in determining complexity, but can contribute in the average investors' inability to understand the risks involved. According to CESR/09-295 a complex instrument requires that an appropriateness test has to be undertaken with clients for non-advised services. Given the use of derivatives, active management, and investment in emerging markets, the ETF is classified as complex. The reference to 'long-term' in the objective, makes the fund difficult to classify as non-complex. The active approach of the Investment Manager, will create a fund that is not simple to understand. Also, in the MiFID II supervisory briefing by ESMA, the use of derivatives is central to the complex asset classification"
    }
}