{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Indices",
            "Potential use of derivatives for direct investment"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as complex based on the MiFID II framework, primarily due to the nature of its benchmark index. While the ETF benefits from the UCITS presumption of non-complexity and uses physical replication, which are factors leaning towards a non-complex classification, this is overridden by the complexity of its investment strategy.The benchmark, the MSCI EM Select Value Factor Focus Index, is a 'smart beta' or 'factor' index. Its construction is not based on a simple market-capitalization weighting but on a quantitative screening process using three specific financial metrics (price-to-future-earnings, price-to-book, and enterprise-value-to-operating-cash-flow). Understanding the methodology, the rationale behind these factors, and the specific 'Factor Focus Risk' (as explicitly mentioned in the KIID) requires a level of financial knowledge beyond that of a typical retail investor. This violates the core 'Ease of Understanding' principle of MiFID II.Furthermore, while the fund is physically replicated, the KIID states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes.' This language is broad and goes beyond simple Efficient Portfolio Management (EPM), introducing potential for structural complexity and risks that are difficult for a retail investor to assess, even if derivatives are not the primary tool. The presence of securities lending also introduces counterparty risk. In synthesis, the complex, rules-based nature of the factor index is the decisive element that makes the ETF's risk and return profile difficult for an average retail investor to understand, thus warranting a 'complex' classification."
    }
}