{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Quantitative investment process"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives for both efficient portfolio management and investment purposes, which introduces additional complexity. The quantitative investment process focusing on risk premia factors (value, quality, momentum, low risk, and size) adds another layer of complexity that may not be easily understood by retail investors. While the ETF is physically replicated, the use of derivatives beyond EPM and the active management strategy with significant deviations from the benchmark contribute to its classification as complex under MiFID II.",
    "confidence": 85,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "investment_leverage_risk": true,
    "exchange_rate_risk": true,
    "operational_risk": true,
    "benchmark_complexity": "S&P 500 Index (non-complex)",
    "additional_notes": "Although the ETF does not use leverage or swaps, the combination of derivatives for investment purposes and the quantitative active management strategy warrants a 'complex' classification. The KIID explicitly mentions that derivatives can behave unexpectedly and highlights investment leverage risk, which further supports this classification."
}