{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "complex": false,
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The Invesco FTSE RAFI Europe UCITS ETF uses physical replication and aims to track the FTSE RAFI Europe Index, which is a well-defined index consisting of large European companies. The document indicates that any derivatives used are limited to efficient portfolio management (EPM). The structure of the ETF and the risks involved are straightforward and should be easily understood by a retail investor with basic knowledge. There is securities lending but it is managed. There is no leverage or capital protection mentioned, and the underlying index is transparent, supporting the non-complex classification. According to the ESMA guidelines, any derivative use is considered complex, however the document indicates its use is limited to EPM. Since the ETF does not use derivatives as an inherent part of its investment strategy and uses physical replication, the ETF should be classified as non-complex. The fund is authorized under the UCITS directive. The risk profile is high but that is not a driver for the complexity classification."
    }
}