{
    "success": true,
    "response": "```json{  'leverage': false,  'derivatives': true,  'swaps': true,  'inverse': false,  'replication_method': 'synthetic',  'ucits': true,  'type': 'ETF',  'complex_factors': [    'Swaps (integral to investment objective)',    'Synthetic Replication',    'Counterparty Risk',    'Opacity of structure (holding non-index securities)'  ],  'classification': 'complex',  'supporting_data': 'The Invesco NASDAQ-100 Swap UCITS ETF is classified as 'complex' despite being a UCITS compliant fund. While UCITS ETFs are generally presumed non-complex (Rule 1), this presumption is overturned by the Fund's specific features. The Fund explicitly states its objective is achieved through the use of 'unfunded swaps' (Rule 2). This is not for efficient portfolio management (EPM) but is integral to its core investment objective of replicating the NASDAQ-100 Index. This direct and central use of swaps immediately triggers a 'complex' classification, as per the explicit rule: 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex''. The replication method is clearly 'synthetic replication' using these swaps (Rule 3), where the Fund holds a basket of equities and equity-related securities that are 'not contained in the Index' and swaps their performance for the index's. This introduces opacity and risks such as counterparty risk and collateral risk (Rule 2, 3), which are highlighted in the KID under 'Use of Derivatives for Index Tracking Risk' and 'Synthetic ETF Risk'. The explanation of unfunded swaps and the mechanism of exchanging cash flows and holding non-index securities make the Fund's structure and payoff difficult for an average retail investor with basic knowledge to understand (Rule 4). Although the underlying NASDAQ-100 Index is transparent, the ETF's synthetic structure overrides this for complexity assessment. There is no indication of significant leverage or other complex features like capital protection structures or complex bonds beyond the inherent complexity of synthetic replication using swaps. The risk indicator (SRI 6/7) reflects market volatility but does not negate the structural complexity introduced by the use of swaps for replication.'}```",
    "note": "Response was not in expected JSON format"
}