{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Swaps",
        "classification": "complex",
        "supporting_data": "The Invesco NASDAQ-100 Swap UCITS ETF uses unfunded swaps as its core replication method.  While the KID mentions purchasing some securities not in the index, the use of swaps to achieve its investment objective is central to its strategy.  This synthetic replication introduces counterparty risk, which is a key factor in determining complexity under MiFID II. Even though it is a UCITS ETF and the index itself is relatively transparent, the reliance on swaps to replicate index performance makes it difficult for retail investors with basic knowledge to understand the full range of associated risks.  The ESMA guidelines and the CESR consultation paper emphasize that derivative use, especially for core replication strategies, usually renders a product complex."
    }
}