{
    "success": true,
    "data": {
        "leverage": true,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for investment purposes",
            "Leverage",
            "Complex active strategy using quantitative models"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, which creates a presumption of non-complexity, this presumption is definitively overturned by several key features outlined in the KIID. The fund is classified as complex primarily because it explicitly states that financial derivative instruments (FDIs) will be used 'for investment purposes in order to achieve the investment objective of the Fund' and may be used to 'generate varying amounts of market leverage'. Under MiFID II rules, the use of derivatives as an integral part of the investment strategy, rather than solely for efficient portfolio management (EPM), renders a product complex. The potential for leverage further solidifies this classification, as it introduces risks and a payoff structure that are difficult for a retail investor to understand. Additionally, the fund's active management strategy relies on 'quantitative (i.e. mathematical or statistical) models' for stock selection, which adds a significant layer of opacity and complexity. The KIID also highlights 'Counterparty Risk' associated with derivatives, a key risk factor that regulators consider difficult for retail investors to assess. Therefore, despite being a UCITS ETF with a physical holding approach, the fund's core strategy and use of complex instruments require a 'complex' classification.",
        "final_assessment": "Complex"
    }
}