{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Factor investing methodology"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to replicate the MSCI Europe Momentum Index, which selects equities based on recent price increases. The fund uses physical replication, investing in the underlying equity securities. While the index methodology itself is based on a 'factor' (momentum), this does not inherently make the ETF complex under MiFID II. The use of physical replication is straightforward. The KID mentions that 'optimising techniques' may be used, including financial derivative instruments (FDIs), for 'direct investment purposes'. However, the primary investment strategy is physical replication. The KID also states that the Fund may engage in short-term secured lending to generate income, which is a common practice and does not automatically render an ETF complex. The risk and reward profile indicates a risk level of six out of seven, primarily due to the nature of its equity investments and factor focus, which leads to less diversification than a parent index. This is market risk, not structural complexity. Importantly, there is no mention of synthetic replication, embedded derivatives integral to the strategy, or complex underlying assets. The index, while factor-based, is described as providing representation of developed European equity markets, suggesting a degree of transparency in its constituents. The ETF is a UCITS, which carries a presumption of being non-complex unless specific features dictate otherwise. The information provided does not indicate any features that would push it into the 'complex' category as defined by MiFID II, such as the use of complex derivatives for replication, structured products, or significant leverage."
    }
}