{
    "name": "Invesco S&P China A MidCap 500 Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly mentions the use of swap agreements and the reliance on counterparties to deliver the benchmark performance, which are key indicators of complexity under MiFID II. Additionally, the ETF is classified as a synthetic replication ETF, which typically involves more complex structures compared to physical replication ETFs. The risk category of 6 also suggests a higher level of risk and complexity.",
    "confidence": 95,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": "The use of swaps and synthetic replication methods may not be easily understood by retail investors, requiring specific knowledge to fully comprehend the risks involved.",
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the reliance on swap agreements and the synthetic replication method are sufficient to classify it as complex under MiFID II. The presence of counterparty risk and the potential for tracking error due to swap pricing spreads further support this classification."
}