{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Derivative Usage for Replication Optimization"
    ],
    "classification": "complex",
    "supporting_data": "The Amundi CAC 40 UCITS ETF Acc primarily uses physical replication to track the CAC 40 Total Return Index. However, the factsheet explicitly mentions the use of OTC swaps with counterparties like Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the exposure is limited to 10% of total assets per UCITS guidelines, the presence of swaps and derivative instruments for replication optimization triggers complexity under MiFID II. Additionally, the counterparty risk disclosures and the potential for tracking error due to derivative usage further support the classification as complex. The ETF's risk profile (SRRI 4) and the use of derivatives beyond simple replication purposes contribute to this determination.",
    "confidence": 85,
    "counter_argument": "The ETF is physically replicated and primarily invests in liquid, large-cap French equities, which are generally straightforward. The derivative usage is limited and within UCITS constraints, and the ETF is PEA-eligible, suggesting it is designed for retail investors. However, the explicit mention of OTC swaps and counterparty risk in the factsheet overrides this argument, as MiFID II considers any significant derivative exposure or counterparty risk as a complexity factor, even if the overall strategy is relatively simple.",
    "risk_level": 4
}