{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "derivatives",
            "counterparty risk",
            "collateral risk"
        ],
        "classification": "complex",
        "supporting_data": "The Fund's objective is to replicate the Indxx Global Cloud Computing v2 Index by investing primarily in equity securities. While the primary replication method is physical, the Fund states it may also invest in financial derivative instruments (FDIs), specifically 'total return' OTC swaps and exchange-traded equity futures, for investment purposes. The inclusion of 'total return' OTC swaps, even if for investment purposes, introduces counterparty risk and collateral risk. MiFID II rules, particularly Article 254 and Delegated Regulation EU 2017/565 Article 57, consider the use of derivatives integral to achieving an investment objective as a factor leading to complexity. The mention of 'total return' OTC swaps signifies a reliance on derivatives for performance replication, which is a key indicator of complexity. Although the document aims to provide exposure to equity securities, the explicit mention of using derivatives to achieve this objective triggers the complexity classification. The document also notes that the Fund may use FDIs to hedge against risk and/or to increase return, and states there is no guarantee of success with derivatives, highlighting their inherent risks. Furthermore, the document lists 'Derivatives Risk' as a key risk factor, noting that derivatives are subject to counterparty risk and are highly sensitive to market movements, reinforcing the complexity. Even if the primary method is physical, the stated ability to use derivatives for investment purposes is sufficient to classify the ETF as complex. ESMA guidelines often flag derivative use, especially when integral to strategy, as a complexity driver due to the associated risks (counterparty, collateral) that are not easily understood by retail investors."
    }
}