{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "optimized",
        "complex_factors": [
            "Derivatives used for replication",
            "ESG index"
        ],
        "classification": "complex",
        "supporting_data": "This is a UCITS ETF which promotes ESG. The fund is passively managed and takes proportionate exposure to the components of the MSCI USA SRI Low Carbon Select 5% Issuer Capped Index (Net Return). Investors may purchase shares through an intermediary on one of the stock exchanges. It is expected that the Fund's resulting ESG rating will be higher than the ESG rating of a Fund tracking a standard index. The fund may use derivatives which can reduce investor risks or give rise to market risks as well as potential loss due to failure of counterparty. The index is designed to measure the performance of best-in-class Environmental, Social and Governance ('ESG') US-based companies while avoiding companies with negative social or environmental impact.",
        "complex": true,
        "non-complex": false,
        "explanation": "This UCITS ETF, while passively managed and tracking an ESG-focused index, is classified as complex under MiFID II due to its potential use of derivatives. The KIID states 'The fund may use derivatives which can reduce investor risks or give rise to market risks as well as potential loss due to failure of counterparty', which raises concerns about counterparty risk and the intricacies of derivative usage, regardless of the stated intent of reducing investor risk. This complexity arises from the difficulty for retail investors with basic knowledge to understand these derivative-related risks. Additionally, the ESG nature of the index involves understanding ESG ratings, which might not be straightforward for all retail investors. Although UCITS ETFs are presumed non-complex, the derivative usage overrides this presumption."
    }
}