{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Derivatives (FDIs) use for direct investment purposes.",
            "ESG criteria limitations",
            "Securities Lending"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, presumptively non-complex, the documentation mentions the use of Financial Derivative Instruments (FDIs) for direct investment purposes, as well as securities lending and an ESG overlay. The use of derivatives beyond efficient portfolio management, especially for direct investment to achieve the Fund's investment objective, introduces complexities like counterparty and collateral risks, potentially exceeding investor understanding. The ESG screening may reduce the potential investment universe and this may adversely affect the value of the Fundu2019s investments compared to a fund without such screening. The fund obtains limited exposure to securities considered not to satisfy these ESG criteria through financial derivative instruments (FDIs) (i.e. investments the prices of which are based on one or more underlying assets) and units in collective investment schemes.. Securities lending introduces counterparty risk. These factors override the UCITS presumption, making the ETF complex for MiFID II purposes."
    }
}