{
    "fund_name": "Invesco FTSE 250 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Unfunded Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly states that the fund enters into swap agreements to exchange the performance of securities not in the index for the performance of the FTSE 250 Index. This synthetic replication method, combined with the reliance on counterparties, makes the product complex under MiFID II. Additionally, the risk category of 6 and the extensive disclosures about counterparty risk further support this classification.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "benchmark_complexity": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of unfunded swaps and synthetic replication is sufficient to classify it as complex under MiFID II. The PRIIPs KID and factsheet confirm the swap fee and the synthetic nature of the replication, reinforcing the complexity assessment."
}