{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps for investment purposes",
            "Futures for investment purposes",
            "Counterparty risk due to derivative use"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is classified as a UCITS ETF, which typically benefits from a presumption of non-complexity under MiFID II. However, this presumption is overturned due to the explicit use of Financial Derivative Instruments (FDIs) for 'investment purposes', specifically 'total return u201cunfundedu201d OTC swaps and exchange-traded equity futures'. The provided MiFID II rules clearly state that if derivatives are integral to achieving the investment objective (beyond efficient portfolio management u2013 EPM) or if any swap usage is identified, the asset is classified as complex. The KII document indicates that these derivatives are used for 'investment purposes' when it's 'not possible or practicable to continue to hold all of the component securities of the Index', implying they are used for index replication. This introduces counterparty risk and collateral risk, which are identified as complex features difficult for retail investors to understand. While the primary replication method is physical, the allowance and explicit mention of unfunded swaps for investment purposes pushes it into the complex category, as derivatives are not solely used for EPM. The fund's risk profile (category 7) also highlights derivatives risk and counterparty risk as key factors."
    }
}