{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Collateralised Loan Obligations (CLOs)",
            "Complex Underlying Index"
        ],
        "classification": "complex",
        "supporting_data": "The Janus Henderson Tabula EUR AAA CLO UCITS ETF invests at least 80% of its Net Asset Value in eligible CLOs rated AAA. The KID explicitly states that CLOs carry risks associated with the underlying loans and the CLO structure governing the priority of payments. These include liquidity risk, interest rate risk, credit risk, prepayment/extension/call risk, and dependence on CLO managers. The fact that the ETF aims to outperform a specific index (J.P. Morgan European Collateralised Loan Obligation Index AAA sub-set) also suggests a potentially complex underlying strategy, especially given the nature of CLOs. MiFID II guidelines and ESMA's interpretation (specifically referencing CESR/09-295) indicate that instruments with complex underlying assets or structures, where risks are not easily understood by a retail investor, are considered complex. CLOs, with their multi-layered structure and dependence on underlying loan performance and credit quality, fall into this category, making the ETF complex due to the inherent difficulty for an average retail investor to fully grasp the associated risks and payoff mechanisms."
    }
}