{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The SPDR S&P 500 UCITS ETF is a physically replicated fund that directly holds the underlying securities of the S&P 500 Index. The KIID explicitly states that the fund uses a replication strategy to create a near mirror-image of the index and primarily invests in securities included in the index. While the fund mentions the use of financial derivative instruments for efficient portfolio management, this is a common practice for UCITS ETFs and does not constitute a complexity trigger under MiFID II. The fund has a straightforward investment objective, a clear risk profile (category 6 due to market volatility rather than structural complexity), and no leverage or inverse exposure. The absence of synthetic replication, leverage, or complex underlying assets supports the non-complex classification.",
    "confidence": 95,
    "counter_argument": "Some might argue that the mention of derivatives could indicate complexity. However, the derivatives are used solely for efficient portfolio management (e.g., hedging or reducing transaction costs) rather than as a core part of the investment strategy. The fund's physical replication and transparent structure outweigh this concern, aligning with MiFID II's non-complex criteria for ETFs.",
    "risk_level": 6
}