{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active management via proprietary quantitative model",
            "Use of derivatives with risk of loss greater than investment",
            "Counterparty risk",
            "Potential investment in complex instruments like warrants and options"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which establishes a baseline presumption of being non-complex. However, this presumption is overridden by several factors. The ETF is actively managed using a 'multi-factor proprietary quantitative investment model', which is an opaque strategy that is difficult for a retail investor to understand. The Key Investor Information Document (KIID) explicitly states the fund may use derivatives and warns that 'Certain derivatives may result in losses greater than the amount originally invested'. This level of risk goes beyond simple Efficient Portfolio Management (EPM) and indicates that derivatives are integral to the investment strategy, making the product structurally complex. The KIID also lists 'Counterparty risk' and 'Derivatives risk' as material risks. Furthermore, the fund's policy allows for investment in complex instruments such as 'warrants and other rights to acquire stock' and 'options', which themselves require advanced knowledge to understand. Although the fund uses a form of physical replication and is not leveraged, the combination of an opaque active strategy and the significant, complex risks associated with its use of derivatives and potential holdings classifies it as complex under MiFID II."
    }
}