{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETP",
        "replication_method": null,
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "complex_factors": [
            "Actively managed ETP investing in US listed equities with a dynamic selection and weighting based on technical and fundamental metrics.",
            "Potential for significant loss of capital.",
            "Currency risk not included in risk indicator."
        ],
        "classification": "complex",
        "supporting_data": "The product is an actively managed Exchange Traded Product (ETP) that invests in US listed equities based on a dynamic 'Investment Strategy'. This active management, as opposed to a passive index tracking, introduces complexity. The ETP states that 'weightings and selections of those stocks...are rebalanced on a quarterly basis, using a range of technical and fundamental metrics.' This dynamic approach to portfolio construction is more complex for a retail investor to understand compared to a static index. Furthermore, the explicit statement 'there is no capital protection against market risk' and 'you may lose some or all of your investment' combined with a risk indicator of '4 out of 7' suggests a level of risk that, when coupled with the active management strategy, pushes it towards complexity. The presence of currency risk, not factored into the main risk indicator, also adds a layer of complexity. While not explicitly stating the use of derivatives for replication, the active management and rebalancing could imply their use or at least a complex selection process that is not easily understood by an average retail investor. The KID also includes a 'comprehension alert': 'You are about to purchase a product that is not simple and may be difficult to understand.', which is a strong indicator of complexity."
    }
}