{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage (total return unfunded OTC swaps)",
            "Derivatives integral to investment objective",
            "Counterparty risk from unfunded swaps",
            "Collateral risk implications from unfunded swaps",
            "Opaque structure due to synthetic replication elements"
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which typically benefits from a presumption of non-complexity. However, this presumption is overturned by the explicit use of financial derivative instruments (FDIs), specifically 'total return unfunded OTC swaps and exchange-traded equity futures for investment purposes'. The provided MiFID II rules state that an ETF is 'complex if derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index's performance.' The KIID confirms that these derivatives are used for 'investment purposes', making them integral to the fund's strategy, not just for efficient portfolio management (EPM). Furthermore, the strict instruction 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex'' directly mandates a complex classification. The use of 'unfunded' OTC swaps introduces additional counterparty and collateral risks that are difficult for retail investors to understand. While the fund also uses physical replication 'primarily', the presence and integral nature of the synthetic components (swaps) are decisive. The fund's high-risk rating (7/7) further highlights the inherent risks, some of which (like counterparty risk) stem directly from its complex structure, aligning with the MiFID II rule that 'risk contributes to complexity only if tied to complex mechanisms'. Therefore, due to the integral use of swaps for investment purposes and the associated risks, the fund is classified as complex."
    }
}