{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Synthetic Replication",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The classification is 'complex' primarily because the ETF uses synthetic replication to achieve its investment objective. The Key Investor Information Document explicitly states that the Fund 'invests in financial derivative instruments (FDIs)' and will 'enter into unfunded total return swaps in order to achieve its investment objective'. This use of derivatives is central to the strategy, not for efficient portfolio management. This structure introduces significant counterparty risk, which is highlighted in the KIID under 'Particular risks not adequately captured by the risk indicator'. The document notes: 'The Fundu2019s ability to track the benchmarku2019s performance is reliant on the counterparties to continuously deliver the performance of the benchmark in line with the swap agreements (i.e. counterparty risk)'. According to MiFID II rules, an instrument is complex if its structure or risks, such as those associated with swaps and counterparty default, are difficult for a retail investor to understand. The use of total return swaps as the core mechanism for index tracking firmly places this ETF in the complex category."
    }
}