{
    "fund_name": "Avantis Global Equity UCITS ETF USD ACC",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Avantis Global Equity UCITS ETF is a physically replicated, actively managed equity ETF that does not employ leverage, derivatives, or swaps as part of its core strategy. The fund invests directly in equities and equity-related securities, with no mention of synthetic replication, leverage, or complex underlying assets like contingent convertible bonds. The risk profile is rated at 6, which is relatively high, but this is due to the equity market exposure rather than structural complexity. The fund explicitly states it does not invest in contingent convertible bonds or use derivatives beyond what may be embedded in certain equity-related securities (e.g., convertible bonds, which are sold as soon as practicable). The KIID does not contain any 'comprehension warnings' or indications of complexity under MiFID II rules. The fund is UCITS-compliant, which generally aligns with non-complex classifications unless specific complex features are present.",
    "confidence": 95,
    "counter_argument": "Some might argue that the high risk rating (6) or the inclusion of convertible bonds (even if temporary) could introduce complexity. However, the convertible bonds are explicitly excluded from the fund's strategy, and the risk rating is a function of equity market volatility rather than structural complexity. The fund's straightforward physical replication and lack of leverage or derivatives support the non-complex classification.",
    "risk_level_assessment": "The fund's risk level is high (6 out of 7) due to its equity market exposure, but this does not equate to structural complexity under MiFID II. The risks are typical of equity investments and are clearly disclosed."
}