{
    "fund_name": "Amerant Latin American Debt UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Contingent Convertible Bonds (CoCos)",
        "High-Yield Fixed-Income Securities Risk",
        "Active Management Risk"
    ],
    "classification": "complex",
    "supporting_data": "The fund invests in Contingent Convertible Bonds (CoCos), which are complex instruments with features such as discretionary coupon cancellation and principal write-downs. These characteristics introduce significant complexity, including the potential for total loss of principal and income. Additionally, the fund's exposure to high-yield fixed-income securities and active management risk further contributes to its complexity. While the fund does not use derivatives or leverage, the inclusion of CoCos and the associated risks make it unsuitable for retail investors without specialized knowledge.",
    "confidence": 90,
    "risk_level": 4,
    "counter_argument": "The fund could be argued as non-complex due to its physical replication method and lack of leverage or derivatives. However, the presence of CoCos and their inherent complexity override this argument, as these instruments introduce risks that are not easily understood by retail investors, aligning with MiFID II's criteria for complex instruments.",
    "additional_notes": "The fund's risk level is categorized as 4, which is relatively high for a fixed-income ETF, further supporting its classification as complex. The KIID explicitly states that the fund may not be appropriate for short-term investment, indicating additional layers of risk and complexity."
}