{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The Xtrackers II EUR Overnight Rate Swap UCITS ETF uses derivatives (specifically, overnight rate swaps) as a core component of its investment strategy to track the Solactive u20acSTR +8.5 Daily Total Return Index.  This synthetic replication method introduces counterparty risk, which is the risk that the counterparty to the swap may default on its obligations. The KID also states that the fund may suffer losses due to these derivative transactions and interest rate volatility. The use of derivatives, and the associated counterparty risk, are significant factors that make this ETF complex under MiFID II, even though it is a UCITS-compliant ETF and uses no leverage.  The complexity of the index itself (while based on a relatively simple underlying interest rate) and the involvement of financial contracts (derivatives) are hard for a retail investor to fully understand without specialized financial knowledge.  Even if the risks are deemed mitigated to some extent, the presence of swaps is enough to classify it as complex."
    }
}