{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active Management",
            "Quantitative Strategy"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as complex. Although it is a UCITS ETF that uses physical replication and does not employ leverage or swaps, its investment strategy is the primary driver for a complex classification. The fund is actively managed and does not seek to track its benchmark. Instead, it relies on a proprietary 'quantitative investment model' and an 'optimisation process' to select stocks based on Value, Quality, and Momentum factors. This active, model-driven strategy makes the ETF's risks and payoff structure opaque and difficult for a typical retail investor with basic knowledge to understand, which is a key condition for complexity under MiFID II Article 25(4) and the provided rules framework (Rule 4). The risk profile is not limited to simple market risk but also includes model risk, which is a concept requiring advanced understanding. While the fund uses FX forwards for currency hedging, this is for efficient portfolio management and not the core reason for the complex classification. The active and non-transparent nature of the investment strategy overturns the general presumption of non-complexity for a UCITS ETF."
    }
}