{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage for exposure",
            "Counterparty risk from derivatives",
            "Counterparty risk from securities lending",
            "Derivatives risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is a UCITS fund, which typically presumes non-complexity. However, the fund's investment policy explicitly states it 'may invest up to 10% of its assets in total return swaps and contracts for difference'. While it indicates physical replication as its primary method, the stated allowance for total return swaps for gaining exposure introduces complexity. The provided MiFID II rules and ESMA guidance indicate that even UCITS can be classified as complex if certain features overturn the presumption. Specifically, the rule states that an ETF is 'Complex: The ETF is complex if derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index's performance.' The KID explicitly lists 'Derivatives Risk' and 'Counterparty Risk' as material risks, which are inherently difficult for retail investors to fully understand in the context of swap agreements. Furthermore, the fund engages in securities lending (up to 25% of assets), which also introduces counterparty risk. Crucially, the instruction 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex'' mandates a complex classification due to the explicit mention of 'total return swaps'."
    }
}