{
    "fund_name": "HSBC MSCI CHINA A UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Contracts for difference"
    ],
    "classification": "complex",
    "supporting_data": "The KIID and factsheet indicate that while the ETF primarily uses physical replication, it may invest up to 10% of its assets in total return swaps and contracts for difference. Additionally, derivatives are used not only for efficient portfolio management but also for investment purposes, which introduces complexity. The presence of swap agreements and the potential for significant counterparty risk, as well as the use of derivatives beyond simple hedging, contribute to the classification as a complex instrument under MiFID II. The risk level is categorized as 6, indicating higher volatility and risk, further supporting the complexity assessment.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant and primarily uses physical replication, which typically suggests a non-complex classification. However, the use of derivatives for investment purposes and the potential for up to 10% in swaps and contracts for difference introduce elements that require specialist knowledge to fully understand, thus overriding the non-complex argument.",
    "risk_level": 6
}