{
    "success": true,
    "response": "```json{  'leverage': false,  'derivatives': true,  'swaps': true,  'inverse': false,  'replication_method': 'synthetic',  'ucits': true,  'type': 'ETF',  'complex_factors': [    'Swaps',    'Synthetic Replication',    'Counterparty Risk',    'Managerial Discretion over Swap Index'  ],  'classification': 'complex',  'supporting_data': 'The fund is identified as a UCITS ETF, which initially benefits from a presumption of non-complexity. However, this presumption is overturned due to several complex features. The fund explicitly states its investment policy involves entering into 'financial contracts (derivatives) with one or more counterparties relating to the transferable securities and the net or gross total return version of the index (swap index)' to achieve its investment objective. This is a clear indication of synthetic replication, relying on swaps rather than direct physical holding of underlying securities. The MiFID II rules explicitly state that if derivatives are integral to achieving the investment objective, as they are here for index replication, the ETF is considered complex. Furthermore, the provided rules state: 'If any element of Contingent Bonds or any Swap usage is identified then the classification must be complex.' The KID also highlights associated risks such as 'COUNTERPARTY RISK' and 'DERIVATIVES RISK,' noting that the fund's returns are 'dependent on the performance of the derivatives used.' The ability of the Investment Manager to select the 'swap index' at their 'absolute discretion' introduces an additional layer of opacity and complexity not typically found in physically replicated, transparent index-tracking products. While the underlying S&P 500 Index is transparent, the fund's structural reliance on swaps and the discretionary selection of a 'swap index' make its performance and inherent risks difficult for a retail investor with basic knowledge to fully understand. This aligns with the understanding that such structures move the instrument beyond simple, directly understandable investments.'}```**Complex**",
    "note": "Response was not in expected JSON format"
}