{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "synthetic",
        "complex_factors": [
            "Flexible Exchange Options (FLEX Options)",
            "Actively managed strategy",
            "Target Outcome Period",
            "Upside Cap",
            "Buffer (15% loss protection)",
            "Derivatives as a primary investment strategy",
            "Potential change in Upside Cap",
            "Exposure to Nasdaq-100 index returns, subject to a cap and buffer"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is UCITS compliant but uses an actively managed investment strategy that invests substantially in FLEX Options which reference the Nasdaq-100 Index. The fund's objective is to provide returns that match the index's price returns up to a predetermined upside cap, while providing a buffer against the first 15% of index losses. However, the returns of the Fund are subject to a cap for the Target Outcome Period. The current Upside Cap will be available on the Fundu2019s website. Unlike other investment products, the potential returns an investor can receive from the Fund are subject to the pre-determined Upside Cap that represents the maximum percentage return an investor can achieve from an investment in the Fund for an entire Target Outcome Period (before fees and expenses). In the event the Index experiences gains over a Target Outcome Period, the Fund seeks to provide investment returns that match the percentage increase of the Index, but any percentage gains over the amount of the Upside Cap will not be experienced by the Fund or its investors. Because of the fund's investment in financial derivative instruments for investment purposes and the complex risk mitigation stratigies it is classified as Complex under MiFID II because a potential investor will require a high degree of sophistication to fully understand all aspects of the product",
        "complex": true,
        "non_complex": false,
        "explaination": "The UCITS ETF employs a complex investment strategy that relies heavily on Flexible Exchange Options (FLEX Options) to achieve a target outcome involving a buffer against losses and an upside cap. The active management, the use of derivatives as a primary investment strategy, the variable upside cap, and the target outcome period all contribute to a structure that is difficult for the average retail investor to understand. According to MiFID II rules and ESMA guidance, this classifies the ETF as complex."
    }
}