{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Index"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF using physical replication, and derivatives are stated to be for Efficient Portfolio Management (EPM) only, which are factors that typically support a non-complex classification. However, the MiFID II assessment is driven to 'complex' by the nature of the underlying index. The fund tracks the 'Linked Franklin US Equity Index', which is not a standard market-cap weighted index. It is a 'smart beta' index constructed using a 'transparent multi-factor selection process that applies four investment style factors (quality, value, momentum and low volatility)'. This quantitative, rules-based approach introduces a layer of complexity that is difficult for an average retail investor to understand. The KIID itself highlights 'Index related risk: the risk that quantitative techniques used in creating the Index the Fund seeks to track do not generate the intended result'. An investor needs to comprehend not just market risk but also the specific risks associated with the factor models (e.g., factor underperformance, model risk), which requires advanced knowledge. According to the provided framework, if the underlying index itself is complex, it can render the ETF complex, overriding the UCITS presumption. Therefore, due to the complexity of the index strategy, the ETF is classified as complex."
    }
}