{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The UCITS ETF uses an indirect replication methodology which involves investing in a total return swap (a financial derivative instrument). MiFID II, specifically Article 254 and Delegated Regulation EU 2017/565 Article 57, along with ESMA guidelines, considers the use of derivatives integral to achieving an investment objective as a key indicator of complexity. The document explicitly states that 'Derivatives are integral to the Sub-Fund's investment strategies'. This reliance on swaps introduces counterparty risk, which is a factor that makes the product difficult for retail investors to understand, thus classifying it as complex according to the MiFID II framework. Even though the ETF aims to track an equity index, the synthetic replication method makes it complex."
    }
}