{
    "fund_name": "HSBC FTSE EPRA NAREIT DEVELOPED UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Contracts for difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of derivatives for investment purposes beyond efficient portfolio management (EPM). While it primarily uses physical replication, the KIID explicitly states the fund may invest up to 10% of its assets in total return swaps and contracts for difference, which introduces counterparty risk and potential tracking error complexities. Additionally, the fund may use derivatives for investment purposes, not just for hedging or EPM, which adds a layer of complexity. The presence of these elements, even if limited in percentage, triggers the MiFID II complexity classification because they require a higher level of investor understanding and introduce risks that are not straightforward.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The fund could be argued as non-complex due to its primary use of physical replication and low percentage allocation to derivatives (up to 10%). However, the explicit mention of using derivatives for investment purposes and the potential for significant tracking error due to these instruments outweighs this argument. The MiFID II rules are strict about any use of derivatives beyond EPM, making this ETF complex despite its otherwise straightforward structure."
}