{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for investment purposes (not solely efficient portfolio management)",
            "Explicit use of Total Return Swaps (TRS) for gaining exposure/investment purposes",
            "Hybrid replication strategy, including synthetic elements",
            "Counterparty risk arising from derivative use and securities lending",
            "Investment leverage risk associated with derivative use"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is identified as a UCITS ETF, which initially carries a presumption of non-complexity. However, the provided MiFID II rules state that this presumption is overturned by certain features. The Key Investor Information Document (KID) explicitly states that the Fund 'may also invest in derivatives... for investment purposes' in addition to efficient portfolio management. Furthermore, the KID specifies that 'The Fund may invest up to 10% of its assets in total return swaps and contracts for difference'. According to the provided rules, 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex'.' This explicit mention of Total Return Swaps, used for 'investment purposes' and to 'gain exposure' when direct investment is not practical, is a primary driver for complexity. While the Fund primarily aims for physical replication by investing in underlying shares, the allowance for derivatives like swaps to achieve its objective means it employs a hybrid model, including synthetic elements, making its replication method 'synthetic' in the context of complexity assessment. The KID also lists 'Derivatives Risk', 'Investment Leverage Risk' (occurring 'when derivatives are used'), and 'Counterparty Risk' as material risks, which are typically beyond the basic understanding of a retail investor and contribute to the product's overall complexity. The Fund's engagement in securities lending (up to 25% of assets) further adds to the counterparty risk profile."
    }
}