{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivative use for index replication/exposure",
            "Counterparty risk from OTC derivatives",
            "Securities lending"
        ],
        "classification": "complex",
        "supporting_data": "The UBS MSCI EMU Select Factor Mix UCITS ETF is indeed a UCITS fund, which typically presumes a non-complex classification. However, this presumption is overturned due to specific features identified in the Key Investor Information Document (KIID) that introduce complexity, aligning with the provided MiFID II assessment rules. The fund states it will gain exposure to the index 'either through direct investments in all or substantially all of the component securities and/or through the use of derivatives in particular where it may not be possible or practicable to replicate the index through direct investments or in order to generate efficiencies in gaining exposure to the index.' This clearly indicates that derivatives are not solely used for efficient portfolio management (EPM), but are integral to achieving its investment objective (index replication/exposure). The MiFID II rules explicitly state that an ETF is complex 'if derivatives are integral to achieving its investment objective, such as using swaps or futures to replicate the index's performance.' The document also mentions 'The use of OTC derivatives further engenders counterparty risk', which is a key indicator of complexity as it is difficult for retail investors to understand. While 'swaps' are not explicitly named as the derivative type, the term 'OTC derivatives' strongly implies instruments like total return swaps, and the rule 'If any element of Contingent Bonds or any Swap usage is identified then the 'classification' must be 'complex'' is a critical factor. Furthermore, the fund 'may enter into securities lending transactions', which, while common, adds another layer of counterparty risk and contributes to the overall complexity. Despite the fund's risk category 6/7 being related to market volatility (equities), the structural use of derivatives and associated counterparty risks are the primary drivers for its complex classification under MiFID II."
    }
}