{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Total Return Swaps for investment purposes",
            "Contracts for Difference for investment purposes",
            "Counterparty Risk",
            "Derivatives Risk",
            "Implicit Leverage through Derivatives",
            "Securities Lending (contributes to counterparty risk)"
        ],
        "classification": "complex",
        "supporting_data": "The Fund, while being a UCITS ETF (generally presumed non-complex), explicitly states it 'may invest up to 10% of its assets in total return swaps and contracts for difference' not only for efficient portfolio management (EPM) but also 'for investment purposes'. The provided MiFID II complexity assessment rules state that if 'any Swap usage is identified then the classification must be complex', and 'If derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index' it is complex. The KII's mention of 'investment purposes' for swaps/CFDs indicates their integral role beyond mere EPM. The fund's risk profile also explicitly highlights 'Counterparty Risk' and 'Derivatives Risk' as material risks, which are directly associated with the use of these complex instruments and require advanced understanding beyond basic financial literacy. Furthermore, the KII mentions 'Investment Leverage' occurring 'when the economic exposure is greater than the amount invested, such as when derivatives are used,' implying that the derivatives used for investment purposes can introduce leverage. While the primary replication method is physical, the explicit use of total return swaps and contracts for difference for investment purposes, and the associated risks (counterparty, derivatives, leverage), are structural features that make the ETF complex for a retail investor to fully comprehend."
    }
}