{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The First Trust Bloomberg Scarce Resources UCITS ETF is a physically replicated, full-replication ETF that tracks the Bloomberg Scarce Resources Index. The KIID and factsheet confirm it uses physical replication of equity securities, with no mention of synthetic replication, swaps, or derivative instruments beyond what might be used for efficient portfolio management (EPM). The risk level is high (SRRI 7), but this is due to the volatility of the underlying equities rather than structural complexity. The fund's objective is straightforward index tracking, and while it invests in sectors that may be volatile (energy, commodities-related equities), the structure itself is transparent and linear. The factsheet explicitly states 'Physical - Full Replication' as the replication method, and there are no indications of leverage, inverse strategies, or complex underlying assets.",
    "confidence": 95,
    "counter_argument": "The high SRRI (7) might suggest complexity, but this is a function of the underlying asset volatility (equity sectors like energy and commodities) rather than structural complexity. The fund's physical replication and lack of derivative usage beyond standard EPM practices override this concern under MiFID II guidelines.",
    "risk_level": 7
}