{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Unfunded Swaps used for index tracking. Synthetic ETF Risk.",
        "classification": "complex",
        "supporting_data": "This UCITS ETF, Invesco STOXX Europe 600 Optimised Personal & Household Goods UCITS ETF, is classified as complex due to its use of unfunded swaps. These swaps are used for index tracking to achieve the objective of the ETF, which is to match the performance of the STOXX Europe 600 Optimised Personal & Household Goods Index.  This means the ETF relies on derivatives for its core function and is therefore more complex than an ETF using physical replication. The ETF also states that it may purchase securities not contained in the index and enter into swap agreements to exchange the performance of those securities for the performance of the reference index. ESMA considers this type of derivative use to be a major factor in classifying a fund as complex and increases counterparty risk, which retail investors may not readily understand. This is further substantiated by the fact the KID document includes a 'risk' factor of 6 out of 7, indicating a high level of market risk. As per MiFID II rules, a comprehension alert would be mandatory in the KID. The document does not provide clear details of the indices it tracks and does mention a complex liquidity weighting methodology of the STOXX Europe 600 Supersector Personal & Household Goods Index, making the ETF difficult to understand. Referencing ESMA/2015/187, and the MiFID II Supervisory Briefing on Appropriateness (ESMA35-36-1640), the use of swaps and synthetic replication are clear indicators of complexity. The ESMA guidelines (ESMA35-36-1640) clearly state that funds that incorporate a structure which makes it difficult for the client to understand the risk or return are automatically complex."
    }
}