{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps for investment purposes (Total Return Swaps)",
            "Securities Lending (Counterparty Risk)",
            "Derivative Use for Investment Purposes",
            "Potential Leverage from Derivatives"
        ],
        "classification": "complex",
        "supporting_data": "The HSBC JAPAN SCREENED EQUITY UCITS ETF is indeed a UCITS fund, which typically benefits from a presumption of non-complexity under MiFID II. However, this presumption is explicitly overturned by several factors based on the provided MiFID II complexity assessment rules and the fund's Key Investor Information Document (KIID).Firstly, the KIID states that 'The Fund may invest up to 10% of its assets in total return swaps and contracts for difference.' These derivatives are used to 'gain exposure' and for 'investment purposes', not solely for efficient portfolio management (EPM). The provided rules explicitly state: 'Complex: The ETF is complex if derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index's performance.' Furthermore, a critical override rule provided in the prompt dictates: 'If any element of... any Swap usage is identified then the 'classification' must be 'complex'.' The presence of total return swaps, even for a portion (5-10%) of the assets, immediately triggers this classification.Secondly, while the primary replication method appears to be physical, the use of total return swaps for gaining exposure introduces elements of synthetic replication, which 'introduces opacity... and risks (counterparty, collateral), making it complex.'Thirdly, the fund engages in securities lending for up to 30% (expected 25%) of its assets, which introduces 'Counterparty Risk', listed as a material risk in the KIID. This significantly contributes to a complex classification, as such risks are not easily understood by retail investors with basic knowledge.Finally, the KIID identifies 'Investment Leverage Risk' as a material risk, explicitly stating it occurs 'when the economic exposure is greater than the amount invested, such as when derivatives are used.' This further contributes to the complexity."
    }
}