{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Quantitative models",
        "Counterparty risk from derivatives"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF is physically replicated and primarily invests in US equities with potential use of derivatives for risk management and cost reduction rather than as a core strategy. While derivatives are permitted, they are not used for leverage or synthetic replication, and the fund's risk profile (rated 6) is driven by equity market exposure rather than derivative complexity. The quantitative models used are for stock selection and not for creating complex payoff structures. Counterparty risk is disclosed but is a standard consideration for funds using derivatives for efficient portfolio management.",
    "confidence": 85,
    "risk_level": 6,
    "counterparty_risk": true,
    "esg_screening": true,
    "quantitative_models": true,
    "benchmark_deviation": true,
    "securities_lending": true,
    "additional_notes": "The ETF's use of derivatives is limited to risk reduction and cost efficiency, which does not inherently make it complex under MiFID II. The primary risks stem from equity market exposure and quantitative model limitations rather than derivative-driven complexity. The absence of leverage, inverse strategies, or synthetic replication supports the non-complex classification."
}