{
    "fund_name": "HSBC S&P 500 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for investment purposes",
        "Total return swaps and contracts for difference (up to 10%)",
        "Securities lending (up to 25%)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of derivatives for investment purposes (not just efficient portfolio management) and the potential use of total return swaps and contracts for difference (up to 10% of assets). While the primary replication method is physical, the KIID explicitly states that derivatives may be used for investment purposes, which introduces additional risk and complexity. The presence of swap agreements and the potential for securities lending further contribute to the complexity. The risk profile (category 6) and the extensive disclosures around derivative risks and counterparty risks also support this classification.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication method and straightforward index-tracking objective. However, the explicit mention of derivatives for investment purposes and the potential use of swaps and securities lending override this argument, as these elements introduce additional layers of risk and complexity that may not be easily understood by retail investors.",
    "additional_notes": "The ETF's UCITS compliance and the fact that it is passively managed do not outweigh the complexity introduced by the derivative usage and swap agreements. The KIID's warnings about derivative risks and counterparty risks further reinforce the complex classification under MiFID II."
}