{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "complex_factors": [
            "Swap usage for investment purposes",
            "Counterparty risk",
            "Derivatives for investment purposes",
            "Potential for leverage through derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is a UCITS ETF, which generally presumes non-complexity. However, the Key Investor Information Document (KID) explicitly states that the 'Fund may invest up to 10% of its assets in total return swaps and contracts for difference' and that it may use 'derivatives for efficient portfolio management purposes (such as to manage risk and costs, or to generate additional capital or income) and for investment purposes'. The use of total return swaps and contracts for difference for 'investment purposes' (to gain exposure to the Index, especially when direct investment is not possible) constitutes derivative use integral to the investment objective, not solely for efficient portfolio management. This introduces counterparty risk, which is explicitly listed as a material risk in the KID. Additionally, the KID states 'Investment Leverage occurs when the economic exposure is greater than the amount invested, such as when derivatives are used', indicating that the use of derivatives can introduce leverage. According to the provided MiFID II rules and ESMA guidance (e.g., CESR/09-295, ANNEX I, Sections 2 and 4), instruments that embed a derivative or whose value is derived from another financial instrument/asset, adding a level of complexity to understanding characteristics and valuation, are considered complex. Specifically, the instruction 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex'' is a definitive trigger for complexity. Therefore, due to the explicit use of total return swaps, derivatives for investment purposes, and the associated counterparty risk, the ETF is classified as complex."
    }
}