{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Index Methodology Risk",
            "Factor Focus Risk",
            "Optimising techniques"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF aims to track the MSCI Europe Momentum Index. While the use of derivatives is mentioned, the document states the fund uses 'optimising techniques' which 'may include the strategic selection of certain securities' or 'the use of financial derivative instruments'. However, due to the lack of information regarding the precise role and extent of derivative use, in line with the general MiFID II principle to err on the side of caution, the classification may still be non-complex. Although the index methodology involves selecting stocks based on recent price increases, which could be considered a form of factor investing and hence potentially more complex than simply tracking a broad market index, the risks are disclosed. The fundu2019s use of 'optimising techniques' could make the assessment non-complex. The fund does use securities lending to generate income, but this is a secondary feature, well managed within UCITS rules, the impact is negligible, and the document states the revenue generated. The KID risk scale is a 6/7, which suggests some volatility, but this is market risk, which does not make it a complex product under MiFID II. The ETF does not appear to use significant leverage. Therefore, based on the provided KID information, the ETF does not appear to be complex under MiFID II. The key is the fund does not specifically mention Total Return Swaps, the product aims to track the return of the index and appears to employ optimised replication. Overall the structure and risks are straightforward for retail investors with basic knowledge to understand, so it is non-complex. Refer to the ESMA information above with the question about the shares. Despite the possibility of optimized replication the fact the fund follows the MSCI Europe Momentum Index suggests the need for some complexity of knowledge, but not for the ETF structure itself."
    }
}