{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage (Total Return Swaps)",
            "Counterparty Risk",
            "Derivatives Risk",
            "Investment Leverage Risk",
            "Securities Lending"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is classified as 'complex' due to several factors, overriding its initial UCITS presumption of non-complexity. Firstly, the Key Investor Information Document (KIID) explicitly states that the Fund 'may invest up to 10% of its assets in total return swaps and contracts for difference' and that derivatives may be used for 'investment purposes', not solely for efficient portfolio management (EPM). Total Return Swaps are a form of synthetic replication and are considered integral derivatives, introducing risks that are difficult for retail investors to understand, such as 'Counterparty Risk' and 'Derivatives Risk', which are explicitly listed as 'Material risks not fully captured by the Risk and Reward Indicator' in the KIID. Per the provided MiFID II rules, 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex''. This is a definitive trigger for complexity. Additionally, the KIID mentions 'Investment Leverage Risk' occurring 'when the economic exposure is greater than the amount invested, such as when derivatives are used', further contributing to complexity. The Fund also engages in 'Securities lending transactions for up to 30% of its assets', which introduces additional counterparty risk, another factor contributing to its complex classification. While the primary replication method is physical, the explicit allowance and use of total return swaps for investment purposes, even if partial, aligns with features that render an ETF complex under MiFID II."
    }
}