{
    "name": "First Trust US Momentum 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 US Momentum iNDEX Index, which consists of 180 high-momentum US equities. The KIID and factsheet confirm full physical replication with no mention of derivatives, swaps, or leverage. The risk level is rated 6, but this is due to market volatility rather than structural complexity. The ETF is UCITS-compliant, has a straightforward fee structure, and provides daily transparency of holdings. The index methodology is rules-based and transparent, with no evidence of complex underlying assets or strategies.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "While the risk level (6) might suggest complexity, it is driven by market volatility rather than structural features. The physical replication method and absence of derivatives or leverage confirm its non-complex classification under MiFID II."
}