{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for income generation",
            "Counterparty risk from derivatives and securities lending",
            "Actively managed fund of funds structure",
            "Use of quantitative models"
        ],
        "classification": "complex",
        "supporting_data": "The fund is classified as UCITS, which typically presumes non-complexity. However, this presumption is overturned by several factors. The fund is actively managed and uses quantitative models, which adds a layer of complexity compared to a passive, index-tracking ETF. Crucially, the fund explicitly states it uses 'financial derivative instruments' not only to 'reduce risk' and 'reduce investment costs' (which would align with Efficient Portfolio Management - EPM), but also to 'generate additional income'. This goes beyond standard EPM. The provided MiFID II rules state, 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex'.' The use of derivatives for 'additional income' strongly implies the potential involvement of swaps or other complex derivative structures, triggering this specific rule. Furthermore, the Key Investor Information Document explicitly lists 'Counterparty Risk' as a particular risk, specifically mentioning 'acting as counterparty to derivatives or other instruments', which directly ties into the complexity introduced by derivatives use and securities lending (also engaged in for additional income). While the fund invests in other UCITS ETFs, its own active management strategy, coupled with the stated use of derivatives for income generation and the explicit counterparty risk, makes its structure, risks, and payoff more difficult for an average retail investor to understand, thereby overturning the UCITS presumption of non-complexity."
    }
}