{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The iShares MSCI USA ESG Enhanced UCITS ETF (IE000U7L59A3) appears to be a non-complex ETF based on the provided information. It aims to track the MSCI USA ESG Enhanced Focus CTB Index using physical replication, holding the equity securities which make up the Index. The ETF employs a binding and significant ESG optimisation approach with the intent to replicate the Index by holding the equity securities which make up the Index, in similar proportions to it. The investment manager may use financial derivative instruments (u201cFDIsu201c) for direct investment purposes to produce a similar return to its Index. The ETF's use of derivatives is limited to producing a similar return to its Index and for currency hedging purposes, which the ESMA guidelines refer to. There is currency hedging which does not make the instrument complex, however the potential for derivative usage for direct investment purposes means the ETF may be open to be classified as a complex instrument. Based on the fact it uses physical replication and does not heavily use derivative instruments the ETF can be classified as non-complex. There are no features that suggest complexity in terms of the underlying index, leverage, or structure, and the replication method is physical, which supports a non-complex classification. The KID specifies that the Fund is suitable for medium to long term investment, though the Fund may also be suitable for shorter term exposure to the Index.",
        "ESMA_references": [
            "This classification is based on ESMA's guidelines on complex and non-complex financial instruments, particularly regarding the use of derivatives for efficient portfolio management (EPM), the replication method, and ease of understanding for retail investors, per section 2.2 of the ESMA document. The main driver for the classification decision is the use of physical replication and the aim of achieving returns similar to its index, which indicates a straightforward structure. ",
            "In line with ESMA's supervisory briefing on appropriateness, the ETF appears to meet the criteria for a non-complex product as it provides services other than those referred to in paragraph 4, which indicates that the service is non-advised, making the appropriateness test applicable (section 2.1)",
            "As per section 2.1 (16) of the ESMA document, the ETF has the optional exemption of using the appropriateness test, which makes the ETF non-complex under MiFID II"
        ]
    }
}