{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Derivatives used for investment purposes (swaps, futures)",
            "Counterparty risk",
            "Collateral risk",
            "Potential for currency risk not fully hedged"
        ],
        "classification": "complex",
        "supporting_data": "The Fund's investment objective is to replicate the performance of the Solactive E-commerce v2 Index. It explicitly states that it may invest in 'financial derivative instruments (FDIs), namely, total return u201cunfundedu201d OTC swaps and exchange-traded equity futures for investment purposes.' The use of derivatives for investment purposes, as opposed to purely efficient portfolio management, introduces complexities related to counterparty risk and collateral management. MiFID II regulations and ESMA guidelines classify instruments where derivatives are integral to achieving the investment objective as complex. Although the ETF uses physical replication primarily, the mention of using OTC swaps and futures for investment purposes triggers a complex classification. Furthermore, the KIID mentions currency risk which, if not perfectly hedged, can add another layer of complexity for retail investors. The ESMA guidelines, specifically referencing Article 4(1)(18)(c) of MiFID Level 1, state that securities giving the right to acquire or sell other transferable securities or giving rise to a cash settlement determined by reference to transferable securities, currencies, interest rates or yields, commodities or other indices or measures, are complex. While the ETF's primary investment is in equity securities, the explicit mention of using total return swaps and futures for investment purposes brings it into the realm of complexity due to the nature of these derivative instruments and their associated risks (counterparty, collateral)."
    }
}