{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": "The ETF invests in below investment grade corporate bonds, which can be difficult for retail investors to understand. The active management of the portfolio also introduces complexity.",
        "classification": "non-complex",
        "supporting_data": "The ETF is a UCITS ETF, which is a key factor for a non-complex classification under MiFID II (MiFID II Art. 19(6)). The ETF aims to outperform the benchmark (ICE BofA Global High Yield Index) by actively investing in a portfolio of below investment grade corporate debt securities. The management company also systematically includes ESG analysis in its investment decisions. The ETF invests at least 67% of its assets in below investment grade corporate debt securities. The fact that it invests in below investment grade bonds introduces complexity and might make an investor struggle to understand the asset as it relies on more complex calculations. The ESMA guidelines and the MiFID II documentation indicates that it is important to provide appropriate information in a clear and comprehensible format, about all financial instruments and proposed investment strategies. This ETF, though, does not use leverage or embedded derivatives and does not use swaps. Based on the information provided the ETF is best described as non-complex, due to its structure and regulatory framework (UCITS).",
        "esma_supporting_data": "ESMAu2019s supervisory briefing indicates that the MiFID II appropriateness requirements are designed to increase investor protection in respect of u2018non-advisedu2019 services (ESMA35-36-1640, paragraph 8). The document identifies the need for firms to have processes in place to distinguish between u2018complexu2019 and u2018non-complexu2019 investment products (ESMA35-36-1640, paragraph 16). The document also addresses the need for the assessment to be in accordance with the proportionality principle and a firmu2019s operational framework (ESMA35-36-1640, paragraph 12). The document highlights the factors that should be covered when determining a clients knowledge and experience (ESMA35-36-1640, paragraph 23). The fact that the ETF invests in below investment grade corporate bonds, however, means that information and warnings should be clear in order to ensure it is not mis-sold to the client."
    }
}