{
    "name": "First Trust SMID Rising Dividend Achievers UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the Nasdaq US Small Mid Cap Rising Dividend Achievers Index, which consists of equities with specific dividend growth characteristics. There is no evidence of leverage, inverse strategies, or synthetic replication. The KIID and factsheet confirm that the fund primarily holds physical securities and does not rely on derivatives or swaps for its core strategy. The risk level (7) is high due to the equity exposure, but this does not inherently indicate complexity under MiFID II. The fund is UCITS-compliant, which generally aligns with non-complex classifications unless specific complex features are present.",
    "confidence": 95,
    "counter_argument": "While the risk level is high (7), this is due to the equity market exposure rather than structural complexity. The absence of derivatives, swaps, or leverage supports the non-complex classification. The fund's strategy is transparent and based on a rules-based index, which is easily understandable for retail investors.",
    "final_decision": "The ETF is classified as non-complex because it uses physical replication, has no leverage or derivatives, and follows a straightforward equity index-tracking strategy."
}