{
    "success": true,
    "data": {
        "type": "ETF",
        "ucits": true,
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Counterparty Risk",
            "Collateral Risk",
            "Difficult to understand risks for retail investors"
        ],
        "classification": "complex",
        "supporting_data": "The AMUNDI S&P 500 BUYBACK UCITS ETF - EUR uses an 'Indirect Replication methodology' which involves investing in a 'total return swap (financial derivative instrument)'. The use of swaps as a core part of the replication strategy, as stated in the KIID, makes the ETF complex under MiFID II due to the inherent risks such as counterparty risk and collateral risk, which are not easily understood by retail investors. Although UCITS ETFs are generally presumed non-complex, the integral use of derivatives for replication overrides this presumption. The KIID explicitly mentions counterparty risk and operational risk, which are key indicators of complexity."
    }
}