{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Active quantitative strategy",
            "Opaque investment model"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which establishes a baseline presumption of being non-complex. It invests directly in equity securities, implying a physical replication method, which also supports a non-complex classification. Derivatives are mentioned for 'efficient portfolio management purposes' only, not as a core part of the strategy, and thus do not automatically trigger a complex classification under the user-provided rules.However, the classification is determined to be 'complex' based on the 'Ease of Understanding' criterion. The KIID states the Sub-Fund is 'actively managed' and the Investment Manager implements a 'multi-factor proprietary quantitative investment model'. This introduces a significant layer of structural complexity. An average retail investor cannot reasonably be expected to understand the mechanics, risks, and payoff structure of a proprietary quantitative model. This opacity makes the fund's strategy difficult to understand, which is a key determinant of complexity under MiFID II. As per ESMA guidelines (e.g., ESMA35-36-1640), a product is complex if it incorporates a 'structure which makes it difficult for the client to understand the risk'. The active, model-driven strategy constitutes such a structure, overriding the non-complex presumptions of it being a UCITS ETF."
    }
}