{
    "fund_name": "Global X SuperDividend UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Unfunded OTC Swaps",
        "Financial Derivative Instruments (FDIs)",
        "Currency Hedging with Derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses 'unfunded' OTC swaps and financial derivative instruments (FDIs) for investment purposes, including total return swaps and equity futures. While the primary replication method is physical, the use of unfunded swaps introduces counterparty risk and complexity beyond standard physical replication. The KIID explicitly mentions derivative risk and counterparty exposure, which are key indicators of complexity under MiFID II. Additionally, the fund's risk category is 6 out of 7, indicating higher volatility and potential complexity in understanding the risk profile.",
    "confidence": 85,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication strategy and UCITS compliance, which typically implies a level of investor protection and transparency. However, the use of unfunded swaps and FDIs for purposes beyond mere efficient portfolio management (e.g., hedging) introduces elements that require specialist knowledge to fully understand the risks involved.",
    "override_reason": "The presence of unfunded swaps and the explicit mention of derivative-related risks in the KIID outweigh the physical replication aspect, as these features introduce additional layers of risk and complexity that are not easily understood by retail investors."
}