{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Derivatives are used for direct investment purposes which may make the ETF complex.",
            "Counterparty risk exists with securities lending.",
            "Index concentration risk: Investment risk is concentrated in specific sectors, countries, currencies or companies."
        ],
        "classification": "complex",
        "supporting_data": "The ETF is UCITS compliant and uses physical replication, which generally suggests non-complexity. However, the document states that the 'investment manager may use financial derivative instruments (FDIs) (i.e. investments the prices of which are based on one or more underlying assets) to help achieve the Fundu2019s investment objective. FDIs (including Foreign Exchange contracts) may be used for direct investment purposes.' The data indicates a potential counterparty risk due to securities lending and index risk. It is classified as risk level 6. The use of FDIs for direct investment is typically regarded as making an ETF complex under MiFID II because this deviates from only using derivatives for efficient portfolio management. This is in addition to counterparty risk relating to securities lending. The ETF tracks the S&P 500 Top 20 Select 35/20 Capped Index, which itself could add some complexity relative to the broader S&P 500, but not enough to override the derivative usage as the primary driver of complexity."
    }
}