{
    "success": true,
    "data": {
        "leverage": true,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Total Return Swaps",
            "Contracts for Difference (CFDs)",
            "Investment Leverage Risk",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF that primarily uses physical replication to track the FTSE 100 index, it is classified as 'complex' under MiFID II. The presumption of non-complexity is overturned by several key factors outlined in the KIID. The Investment Policy explicitly states the fund 'may invest up to 10% of its assets in total return swaps and contracts for difference.' The use of swaps, even for a minor portion of the portfolio, introduces significant complexity and triggers a 'complex' classification as per the provided rules ('If any Swap usage is identified then the 'classification' must be 'complex''). Furthermore, the KIID highlights associated risks that are difficult for a retail investor to understand, including 'Counterparty Risk' and 'Investment Leverage Risk', the latter being a direct result of using derivatives. While the underlying index is transparent, the potential inclusion of these derivative instruments makes the ETF's structure and risk profile opaque and not easily understandable for an average retail investor, mandating a 'complex' classification."
    }
}