{
    "fund_name": "Invesco MSCI USA UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the reliance on swap agreements and counterparty performance, which are key indicators of complexity under MiFID II. Additionally, the risk profile (category 6) and the synthetic replication method contribute to the classification as a complex instrument.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": false,
    "benchmark_complexity": "low",
    "liquidity_risk": "low",
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of unfunded swaps and synthetic replication inherently introduces complexity due to counterparty risk and the need for investors to understand the mechanics of swap agreements. The UCITS compliance and straightforward index-tracking objective do not outweigh the complexity introduced by the synthetic replication method."
}