{
    "success": true,
    "data": {
        "complex": true,
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swap usage for currency hedging (FX forward contracts)",
            "Counterparty risk from derivative use and securities lending"
        ],
        "classification": "complex",
        "supporting_data": "The iShares NASDAQ 100 UCITS ETF is indeed a UCITS compliant Exchange Traded Fund that primarily employs physical replication by holding the underlying equity securities of the NASDAQ 100 Index. The underlying index is transparent and well-understood. However, the document explicitly states the use of Financial Derivative Instruments (FDIs) for currency hedging purposes, specifically mentioning 'FX forward contracts'. FX forward contracts are a type of derivative with swap-like characteristics. The provided MiFID II complexity assessment rules state, 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex'.' This overrides the general presumption of non-complexity for UCITS funds. Furthermore, the Key Investor Information (KID) explicitly identifies 'Counterparty Risk' as a particular risk related to derivatives and securities lending. While these activities (currency hedging and securities lending) are for efficient portfolio management, the introduction of counterparty risk associated with derivative instruments (FX forward contracts/swaps) and the explicit instruction in the prompt dictate a complex classification. Retail investors with basic knowledge may find it difficult to fully understand the intricacies and implications of counterparty risk in such scenarios."
    }
}