{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": false,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [
            "Swaps",
            "ESG exclusionary criteria"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is UCITS compliant. It physically replicates the FTSE Developed ESG Low Carbon Select Index. Up to 10% of the ETF's assets may be invested in total return swaps. Although derivatives are used for efficient portfolio management, this ETF utilizes up to 10% of its assets in total return swaps which increases opacity and counterparty risk, leading to a complex classification under MiFID II. The index itself excludes companies based on ESG criteria, which, while not inherently complex, adds a layer of specific knowledge needed for full understanding. The risk rating on the KID is 6/7, reflecting market volatility. The potential use of swaps, even in a limited amount, suggests counterparty risk, making it harder for a client to easily understand the UCITS ETF, therefore MiFID II would deem it complex."
    }
}