{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Currency hedging using derivatives",
            "Counterparty risk",
            "Complex index methodology"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF, which carries a presumption of being non-complex. However, this presumption is overturned by several factors. The KIID explicitly states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes,' which goes beyond simple Efficient Portfolio Management (EPM) and is a core feature that is difficult for a retail investor to understand. Furthermore, this specific share class is currency-hedged using FDIs (FX forward contracts), which introduces structural complexity and risks, such as the potential for the hedge to be imperfect. The KIID also highlights 'Counterparty Risk' as a particular risk not adequately captured by the SRRI, stemming from the use of derivatives and securities lending. This type of risk is a key indicator of complexity under MiFID II. Finally, the benchmark index, while transparent, follows a strategy based on 'forecasted yield,' which is more complex than a standard market-cap weighted index. The combination of these featuresu2014especially the use of derivatives for direct investment and hedgingu2014makes the ETF's structure and risk profile difficult for an average retail investor to understand, leading to a 'complex' classification."
    }
}