{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": true,
        "swaps": false,
        "leverage": false,
        "inverse": false,
        "complex_factors": [
            "ESG screening",
            "Currency Hedging"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to track the MSCI USA ESG Screened Index. The replication method is physical, meaning it holds the underlying equity securities. The index methodology involves ESG screening and exclusions, which is transparent. While the ETF uses financial derivative instruments (FDIs) for currency hedging, this is for efficient portfolio management and does not appear to be integral to the investment objective or introduce complexity that would be difficult for a retail investor to understand. The use of FDIs for hedging is explicitly mentioned as a non-complex use case in the provided rules. The ETF is a UCITS, which carries a presumption of being non-complex. There are no indicators of leverage, embedded derivatives, or other complex structures that would alter this classification. The ESG screening, while adding a layer to index selection, is based on publicly available criteria and does not inherently make the ETF complex for a retail investor. Currency hedging via forward contracts is a standard practice for UCITS ETFs aiming to provide a hedged share class and is generally understood by retail investors as a mechanism to mitigate currency risk. Therefore, based on the provided information and MiFID II guidelines, the ETF is classified as non-complex.",
        "MiFID_II_guidelines_applied": "1. UCITS Presumption: The ETF is a UCITS, thus presumed non-complex unless specific features indicate otherwise. 2. Derivative Use: Derivatives are used for currency hedging (efficient portfolio management), not integral to the investment objective. This is permissible for non-complex classification. 3. Replication Method: Physical replication is used, which is generally considered non-complex. 4. Ease of Understanding: The objective (tracking an index), structure (physical replication), and risks (market volatility, tracking error, currency hedging effects) are generally understandable for retail investors with basic knowledge. The ESG screening of the index is a transparent methodology. 5. Additional Features: No significant leverage or embedded derivatives are indicated. Securities lending is mentioned but as a secondary income source, and its impact on complexity is not elaborated to suggest it makes the ETF complex. 6. Synthesis: The ETF's core strategy is straightforward physical replication of a screened index. The currency hedging is a common, understandable practice for UCITS. No factors point towards complexity."
    }
}