{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Potential use of derivatives",
            "Securities lending",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is classified as complex. Although it is a UCITS ETF using physical (optimized) replication, which are strong indicators of non-complexity, the UCITS presumption is overturned by several factors. The KIID states the fund 'may obtain indirect exposure (for example, through financial derivative instruments (u201cFDIsu201d))'. While these are likely for Efficient Portfolio Management (EPM) and not central to the strategy, the document explicitly identifies 'Counterparty Risk' as a particular risk, noting 'The insolvency of any institutions... acting as counterparty to derivatives... may expose the Share Class to financial loss.' The introduction of derivative-related counterparty risk, which is difficult for a typical retail investor to understand, is a key indicator of complexity under MiFID II. Furthermore, the fund engages in securities lending to generate income, which also introduces counterparty risk. The combination of these two features adds layers of structural complexity and risk beyond simple market risk, making the product difficult for a retail investor with basic knowledge to fully understand. Therefore, despite the UCITS wrapper and physical replication method, the potential use of derivatives and definite use of securities lending, both introducing counterparty risk, lead to a 'complex' classification."
    }
}