{
    "fund_name": "Invesco NASDAQ-100 Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to replicate the NASDAQ-100 Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the reliance on swap agreements and counterparty performance, which are key indicators of complexity under MiFID II. Additionally, the risk profile is rated at level 6, indicating higher risk and potential complexity. The synthetic replication method and the need for investors to understand counterparty risk further support the classification as complex.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "underlying_assets": "Equities and equity-related securities",
    "benchmark_complexity": "NASDAQ-100 Index (non-complex, but synthetic replication adds complexity)",
    "additional_notes": "While the ETF tracks a well-known index, the use of synthetic replication via swaps and the associated counterparty risks make it complex under MiFID II. The PRIIPs KID and factsheet reinforce the reliance on derivatives and the potential for tracking error due to swap pricing spreads."
}