{
    "success": true,
    "response": "```json{  'leverage': false,  'derivates': true,  'swaps': true,  'inverse': false,  'replication_method': 'synthetic',  'ucits': true,  'type': 'ETF',  'complex_factors': [    'Synthetic replication',    'Integral use of derivatives (total return swaps)',    'Counterparty risk'  ],  'classification': 'complex',  'supporting_data': 'The Sub-Fund is identified as a UCITS ETF, which typically implies a non-complex classification. However, this presumption is overturned by several key features. The ETF explicitly states it uses an 'Indirect Replication methodology' and will 'invest into a total return swap (financial derivative instrument) delivering the performance of the Index against the performance of the assets held.' It further states that 'Derivatives are integral to the Sub-Fund's investment strategies.' According to the provided MiFID II rules, if derivatives are integral to achieving the investment objective (rather than solely for efficient portfolio management), the ETF is classified as complex. Synthetic replication, which relies on total return swaps, introduces risks such as counterparty risk and collateral risk, which are generally considered difficult for retail investors with basic knowledge to understand, as outlined in the 'Ease of Understanding' criterion. The Key Investor Information Document explicitly mentions 'Counterparty risk' as a materially relevant risk. The ESMA guidelines (CESR/09-295, Para 7) reinforce this by stating that 'all derivatives are assumed to be complex because their value is derived from another financial instrument or asset, adding a level of complexity to the understanding of the characteristics and valuation of those instruments.' Furthermore, Article 38(a) of the Level 2 Directive, referenced in the ESMA document, excludes instruments falling under points (4) to (10) of Section C of Annex I to Directive 2004/39/EC (which include swaps) from being considered non-complex. While the underlying index is transparent, the ETF's complex replication structure, involving integral use of swaps, overrides the non-complex presumption.'}```",
    "note": "Response was not in expected JSON format"
}