{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Securities Lending"
        ],
        "classification": "non-complex",
        "supporting_data": "The assessment is based on the MiFID II framework. The fund is a UCITS ETF, which establishes a baseline presumption of being non-complex. The replication method is physical ('it will invest in all of the securities comprising the Index'), which is a key indicator of a non-complex structure as it is transparent and straightforward for an investor to understand. The fund does not use derivatives as an integral part of its investment strategy to track the index. The primary potential complexity factor is the engagement in securities lending, which introduces counterparty risk. However, according to the provided rules, securities lending as a secondary activity for revenue generation does not automatically classify an ETF as complex, provided it is managed within UCITS regulations. The fund's primary risks stem from market and sector volatility (Risk Profile 6/7), not from a complex structure. The underlying index is rules-based and does not appear to have complex features. Given these factors, the UCITS presumption of non-complexity is not overturned."
    }
}