{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "leverage": false,
        "inverse": false,
        "complex_factors": [
            "FTSE EPRA/NAREIT Developed Index (real estate focus could be complex for some)",
            "Securities Lending (counterparty risk)",
            "Potential for derivatives for EPM"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the FTSE EPRA/NAREIT Developed Index, which represents listed real estate companies and REITs. While the underlying asset class (real estate) can be complex for some investors, the index itself is a broad equity index. The replication method is direct replication, meaning it holds the underlying securities, which is generally considered non-complex. The ETF may use derivatives for efficient portfolio management (EPM) to manage inflows/outflows or currency risk, and may also engage in securities lending. According to MiFID II guidelines, limited use of derivatives for EPM with minimal impact on risk-return, and well-managed securities lending, do not automatically classify an ETF as complex. The primary risk factors highlighted are market risk, liquidity risk, and counterparty risk, which are standard for many ETFs and do not inherently point to structural complexity. The absence of embedded derivatives, significant leverage, or opaque structures supports a non-complex classification. The KID emphasizes a minimum holding term of 5 years, which is typical for equity ETFs and does not indicate complexity. The provided ESMA documentation (CESR/09-295 and ESMA35-36-1640) states that UCITS are generally presumed non-complex unless they exhibit specific complex features. This ETF's primary features align with the non-complex presumption."
    }
}