{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "swaps": true,
        "derivatives": true,
        "leverage": false,
        "inverse": false,
        "complex_factors": [
            "Total Return Swaps",
            "Counterparty Risk",
            "Collateral Risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF explicitly states that it 'aims to achieve a return on your investment... which reflects the net total return of the S&P 500 Index'. Critically, it clarifies that 'The Fund is passively managed and invests in financial derivative instruments (FDIs). In particular, it will enter into unfunded total return swaps in order to achieve its investment objective.' The use of total return swaps to replicate index performance is a key indicator of complexity under MiFID II, as it introduces risks such as counterparty risk and collateral risk, which are not easily understood by retail investors. Furthermore, the KIID itself assigns a risk rating of six out of seven, highlighting the inherent risks. The 'Risk and Reward Profile' section explicitly mentions 'Counterparty Risk' and the potential for 'financial loss' if a counterparty defaults or fails to provide sufficient assets. The ETF also mentions investing in 'a portfolio of global developed market equity securities' whose returns are used to pay counterparties, adding another layer of understanding required by investors. Based on these factors, particularly the reliance on unfunded total return swaps as the primary replication method and the associated risks, the ETF is classified as complex."
    }
}