{
    "fund_name": "Invesco FTSE RAFI Emerging Markets UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the FTSE RAFI Emerging Markets Index, which is a fundamental-weighted index based on company metrics like sales, cash flow, book value, and dividends. There is no mention of synthetic replication, leverage, or complex derivatives. The risk profile is categorized as level 6, but this is primarily due to emerging market exposure rather than structural complexity. The fund engages in securities lending, but this is a common practice and does not inherently make the product complex under MiFID II. The KIID and factsheet do not indicate any use of swaps, unfunded derivatives, or other complex instruments. The fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II.",
    "confidence": 95,
    "counter_argument": "Some might argue that the emerging market focus and securities lending introduce complexity. However, these factors alone do not meet the MiFID II criteria for complexity, as they are common in many non-complex ETFs. The absence of leverage, synthetic replication, or sophisticated derivatives is the decisive factor in this classification."
}