{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Counterparty Risk",
            "Collateral Risk",
            "Index Replication Method"
        ],
        "classification": "complex",
        "supporting_data": "The Fund aims to generate returns that closely correspond to the price and yield performance of the Solactive Video Games & Esports v2 Index by investing in equity securities and **financial derivative instruments (FDIs)**, namely **total return 'unfunded' OTC swaps** and exchange-traded equity futures. The use of OTC swaps introduces counterparty risk and collateral risk, which are generally considered complex for retail investors. While the fund aims to track an index, the method described (swaps) indicates a synthetic replication strategy. According to MiFID II guidelines, the use of derivatives integral to achieving the investment objective, as is the case with synthetic replication, leads to a complex classification. Even though the document mentions EPM, the primary mechanism for tracking is via swaps. The ESMA guidance (CESR/09-295) explicitly states that instruments whose value is derived from another financial instrument or asset (like swaps) add a level of complexity, and synthetic replication often makes an ETF complex due to the associated risks (counterparty, collateral) that are not easily understood by retail investors. The KIID also highlights 'Derivatives Risk' and 'Counterparty risk' as key risks, further supporting a complex classification."
    }
}