{
    "fund_name": "HSBC FTSE EPRA NAREIT DEVELOPED UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Total Return Swaps",
        "Contracts for Difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication to track the FTSE EPRA NAREIT Developed Index, which consists of real estate companies and REITs. However, the KIID explicitly states that the fund may invest up to 10% of its assets in total return swaps and contracts for difference, though it is not expected to exceed 5%. This introduces counterparty risk and potential complexity due to the use of derivatives, even if limited. Additionally, the fund may use derivatives for efficient portfolio management, which, while not inherently complex, adds a layer of sophistication. The risk profile is categorized as level 6, indicating higher volatility and potential complexity. The presence of swap agreements and derivative instruments, even for limited purposes, triggers the classification as a complex instrument under MiFID II.",
    "confidence": 85,
    "counter_argument": "The fund is physically replicated and primarily invests in straightforward real estate securities, which are generally considered non-complex. The use of derivatives is limited and primarily for efficient portfolio management, which might not inherently make the fund complex. However, the explicit mention of total return swaps and contracts for difference, even at a limited percentage, introduces elements of complexity that cannot be overlooked under MiFID II guidelines.",
    "risk_level": 6
}