{
    "fund_name": "Avantis Global Small Cap Value UCITS ETF USD ACC",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Avantis Global Small Cap Value UCITS ETF is an actively managed fund that invests primarily in equities and equity-related securities, with no mention of synthetic replication, leverage, or complex derivatives. The fund explicitly states it does not invest in contingent convertible bonds or use swaps for replication. The risk profile is rated at 6, which is high but not necessarily indicative of complexity under MiFID II. The fund's strategy is straightforward, focusing on small-cap value equities in developed markets. There are no indications of complex structures, capital protection mechanisms, or significant counterparty risks. The fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II.",
    "confidence": 95,
    "counter_argument": "The high risk rating (6) might suggest complexity, but this is primarily due to the inherent volatility of small-cap equities rather than structural complexity. The absence of derivatives, leverage, or synthetic replication supports the non-complex classification.",
    "final_reasoning": "The fund is classified as non-complex because it uses physical replication, has no leverage or inverse exposure, and does not rely on complex derivatives or structures. The high risk rating is due to the asset class rather than the fund's construction."
}