{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "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. The KIID explicitly mentions the reliance on swap agreements and the potential financial loss due to counterparty insolvency. Additionally, the ETF is classified as a synthetic replication fund, which inherently involves derivative instruments and counterparty exposure. The risk category is 6, indicating higher risk, and the fund's performance is dependent on the counterparties delivering the benchmark performance as per the swap agreements.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": "The use of swaps and synthetic replication requires understanding of counterparty risk and derivative mechanics, which may not be straightforward for retail investors.",
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the synthetic replication method and the reliance on swap agreements with counterparties introduce significant complexity. The fund's risk profile and the potential for tracking error due to swap pricing spreads further support the classification as a complex instrument under MiFID II."
}