{
    "type": "ETC",
    "ucits": false,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Commodity-linked structure",
        "Unfunded swap exposure",
        "Complex index tracking",
        "Counterparty risk",
        "No capital protection"
    ],
    "classification": "complex",
    "supporting_data": "The product is an open-end tracker certificate linked to the UBS CMCI Copper USD TR Index, which is a complex commodity index. The structure involves synthetic replication through an unfunded swap arrangement, exposing investors to counterparty risk with UBS AG. The KIID explicitly states that 'this product is not simple and may be difficult to understand,' which is a strong indicator of complexity under MiFID II. The risk indicator is 5 out of 7, indicating medium-high risk, and there is no capital protection. The product's performance is directly tied to the underlying index, which itself may involve complex calculations and roll costs associated with commodity futures. The lack of UCITS compliance further supports the complex classification.",
    "confidence": 0.95
}