{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Financial Derivative Instruments (FDIs) for efficient portfolio management",
            "Potential counterparty risk",
            "Potential collateral risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF aims to track the FTSE EPRA/Nareit Developed Dividend + Index. While it primarily uses physical replication by investing in equity securities of listed real estate companies and REITs, the Key Investor Information Document explicitly states that 'financial derivative instruments (FDIs) (i.e. investments the prices of which are based on one or more underlying assets)' may be used for 'efficient portfolio management purposes'. Furthermore, it notes that FDIs 'may be used for direct investment purposes'. MiFID II guidelines, particularly ESMA's, emphasize that the use of derivatives, even for efficient portfolio management, can introduce complexities such as counterparty risk and collateral risk, which may be difficult for retail investors to understand. The document also mentions that the Fund may engage in short-term secured lending, which introduces counterparty risk. Although the ETF's core strategy is physical replication of a real estate index, the explicit mention of the use of financial derivative instruments, even if for EPM, triggers a classification of complex under MiFID II due to the inherent risks associated with derivatives that retail investors may not easily comprehend. The mention of potential counterparty risk and collateral risk further solidifies this classification."
    }
}