{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Swaps",
        "classification": "complex",
        "supporting_data": "The fund is classified as a UCITS ETF, which are generally presumed non-complex under MiFID II due to their regulated nature, as supported by CESR/09-295, Section IV, Paragraph 69 and Annex I, which states that UCITS are automatically non-complex regardless of underlying investments or derivative use for appropriateness purposes. The fund primarily uses physical replication to track the MSCI USA Index, which is transparent. However, the Key Investor Information Document explicitly states that 'The Fund may invest up to 10% of its assets in total return swaps and contracts for difference' and also uses derivatives for 'investment purposes'. It also notes 'Counterparty Risk' as a material risk, which is often associated with derivative use and securities lending (up to 25%). According to the specific instruction provided in the assessment rules: 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex''. The presence of 'total return swaps' directly triggers this complexity classification, overriding the general UCITS presumption based on this specific rule."
    }
}