{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Currency Hedging Derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which creates a presumption of non-complexity. It uses physical replication by holding the underlying shares of the index, which is a non-complex feature. However, this presumption is overturned by the fund's core investment objective, which is to track the 'MSCI USA 100% hedged to CHF Index'. To achieve the currency hedging, the fund uses derivative instruments ('selling foreign currency forwards at one month forward rate'). This use of derivatives is not for simple Efficient Portfolio Management (EPM) but is integral to delivering the fund's specific, hedged return profile. This introduces risks and concepts, such as counterparty risk (which is explicitly mentioned in the KIID) and the mechanics of forward contracts, that are difficult for an average retail investor to understand. According to MiFID II rules, when derivatives are central to the investment strategy and introduce complex risks, the instrument is classified as complex. The ESMA Supervisory Briefing (ESMA35-36-1640) also highlights that a structure making it difficult for the client to understand the risk can lead to a complex classification. The currency hedging overlay constitutes such a structure."
    }
}