{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for investment purposes",
            "Counterparty risk",
            "Collateral risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF uses financial derivative instruments (FDIs), specifically total return 'unfunded' OTC swaps and exchange-traded equity futures, for investment purposes to replicate the Index's performance. The KIID explicitly states that derivatives are subject to counterparty risk, potential loss of instruments, and are highly sensitive to market volatility, which are factors that can make them difficult for retail investors to understand. Although the primary replication method is physical, the use of derivatives for investment purposes, rather than solely for efficient portfolio management, leads to a complex classification. The risk profile also mentions currency risk and that the fund may use FDIs to hedge against negative currency movements, further indicating derivative usage.",
        "esma_guidelines_references": [
            "Section 2.1 Determining situations where the appropriateness assessment is required: 'firms are likely to need processes (i) to distinguish between u201ccomplexu201d and u201cnon -complexu201d investment products; ...'",
            "Section 2.1 Determining situations where the appropriateness assessment is required: 'How policies and processes has the firm set up to identify which of its investment products may be regarded as u201ccomplexu201d for the purposes of the appropriateness requirements? Are such policies and processes regularly updated or reviewed?'",
            "Section 2.1 Determining situations where the appropriateness assessment is required: 'For instance, how is the firm assessing which shares embed a derivative (what are the criteria used)?'",
            "Section 2.1 Determining situations where the appropriateness assessment is required: 'For instance, how is the firm assessing i) which debt instruments embed a derivative or incorporate a structure making it difficult for the client to understand the risk ...?'",
            "Section 2.1 Determining situations where the appropriateness assessment is required: 'Is the firm taking into account ESMAu2019s Guidelines on complex debt instruments and structured deposits dated 4 February 2016?'",
            "Section 2.2 Obtaining information from clients: 'For instance, i s the firm asking questions about the clientu2019s past transactions ,level of education (in the relevant field) and profession or former profession ?'",
            "Section 2.2 Obtaining information from clients: 'Is the level of education or professional experience considered appropriate by the firm tailored to the complexity of the investment product offered or demanded?'",
            "Section 2.3 Assessment of appropriateness: 'Does the firm categorise investment products according to their complexity when carrying out the appropriateness assessment ? Does this categorisation appear reasonable?'",
            "Section 2.3 Assessment of appropriateness: 'How do the firmu2019s arrangements and procedures ensure that the appropriateness of a transaction is assessed against the clientu2019s knowledge and experience ?'",
            "Section 2.4 Warnings to clients: 'Where the appropriateness assessment indicates that a complex and risky investment product is not appropriate for a client, is the warning delivered by the firm overly generic and/or vague?'"
        ]
    }
}