{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Total Return Swaps for investment purposes",
            "Contracts for Difference for investment purposes",
            "Counterparty Risk",
            "Derivatives Risk",
            "Securities Lending"
        ],
        "classification": "complex",
        "supporting_data": "The UCITS ETF is initially presumed non-complex due to its UCITS status. However, this presumption is overturned by several factors related to the use of derivatives. The Key Investor Information document explicitly states the fund 'may invest up to 10% of its assets in total return swaps and contracts for difference' not only for efficient portfolio management but also 'for investment purposes'. According to the MiFID II Complexity Assessment Rules and ESMA guidance (CESR/09-295, Annex I, Section 4), 'MiFID-scope derivatives covered by items 4-10 of Section C of the Annex to MiFID' are 'ALWAYS COMPLEX', and swaps are explicitly listed under Section C(4). The user's specific instruction also mandates that 'If any element of...any Swap usage is identified then the classification must be complex'. Furthermore, while the fund primarily uses physical replication, it states it 'may gain exposure by using other investments such as ... derivatives' if direct investment is not practical, reinforcing the role of derivatives in its strategy for performance. The KII also lists 'Counterparty Risk' and 'Derivatives Risk' as 'Material risks not fully captured by the Risk and Reward Indicator', indicating that these are significant and potentially difficult for retail investors to understand. The presence of 'Investment Leverage Risk' due to derivative use, and securities lending (up to 30% of assets) which introduces additional counterparty risk, further contributes to the complexity. These elements combined make the product's structure, risks, and payoff difficult for an average retail investor to fully comprehend, leading to a complex classification."
    }
}