{
    "name": "Invesco Preferred Shares UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Perpetual Preferred Securities",
        "Subordinated Debt Risk",
        "High Risk Category (6)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to perpetual preferred securities and subordinated debt, which are inherently complex instruments. These securities have no maturity date, can defer payments, and have lower priority in bankruptcy, making them difficult for retail investors to fully understand. Additionally, the high risk category (6) and the specific risks associated with preferred securities (such as deferral of distributions and potential non-redemption) contribute to the complexity. While the ETF uses physical replication and does not employ leverage or derivatives, the underlying assets' complexity and the associated risks make it a complex product under MiFID II.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The ETF uses physical replication and does not employ leverage or derivatives, which are typically indicators of non-complexity. However, the complexity arises from the nature of the underlying assets (perpetual preferred securities and subordinated debt) and their associated risks, which are not easily understood by retail investors.",
    "final_decision": "Despite the straightforward replication method, the inherent complexity of the underlying assets and the high risk profile justify classifying this ETF as complex under MiFID II."
}