{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Potential use of Financial Derivative Instruments (FDIs) for direct investment purposes, which implies possible swap usage. Associated counterparty risk. Factor-based index involves specific financial metrics that may require a deeper understanding for retail investors.",
        "classification": "complex",
        "supporting_data": "The iShares Edge MSCI World Value Factor USD (Dist) Share Class is a UCITS ETF, which typically benefits from a presumption of non-complexity under MiFID II. It primarily uses optimized physical replication, investing directly in the underlying equity securities that make up its benchmark index. The ETF is passively managed and does not employ leverage as a core strategy for returns, nor does it offer capital protection. Its underlying index, while factor-based, is described in the KII and appears transparent in its methodology.However, the Key Investor Information (KII) states that 'Financial Derivative Instruments (FDIs) ... may be used for direct investment purposes. The use of FDIs is expected to be limited for this Share Class.' While the use is stated as 'limited' and part of 'optimising techniques,' the phrase 'direct investment purposes' means FDIs are used to gain exposure rather than solely for efficient portfolio management (EPM). As swaps are a type of FDI, this statement identifies 'potential swap usage.' The provided rules explicitly state: 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex.' This specific instruction overrides the general UCITS presumption of non-complexity.Furthermore, the KII explicitly mentions 'Counterparty Risk' as a particular risk, noting that 'The insolvency of any institutions providing services such as safekeeping of assets or acting as counterparty to derivatives or other instruments, may expose the Share Class to financial loss.' This reinforces the presence of risks related to derivative use that may be challenging for a retail investor to fully comprehend. Although securities lending is a common practice in UCITS ETFs and typically doesn't trigger complexity on its own, it also introduces counterparty risk.While ESMA's 2009 guidance (CESR/09-295, Section 3, Para 69 & 80) states UCITS are 'automatically non-complex,' the later 2019 ESMA Supervisory Briefing (ESMA35-36-1640, Section 2.1) implies that 'structured UCITS' or those with 'algorithm-based payoffs' can be complex. More importantly, the explicit instruction provided for this assessment regarding 'swap usage' serves as a definitive trigger for complexity, regardless of the UCITS label or the primary physical replication method."
    }
}