{
    "fund_name": "Invesco S&P 500 QVM UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco S&P 500 QVM UCITS ETF is a physically replicated ETF that tracks the S&P 500 Quality, Value, and Momentum Multi-Factor Index. It does not use synthetic replication, leverage, or derivatives for purposes other than efficient portfolio management. The fund's risk profile is clearly disclosed, and it follows a straightforward index-tracking strategy. The KIID and factsheet indicate that the fund uses physical replication, holds liquid securities, and has a transparent fee structure. There are no indications of complex underlying assets, capital protection mechanisms, or significant counterparty risks. The fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "While the fund tracks a multi-factor index, which could be considered more complex than a standard market-cap-weighted index, the physical replication method and lack of leverage or derivatives usage for non-EPM purposes keep it within the non-complex classification. The multi-factor approach is still transparent and does not introduce additional risks that would require specialist knowledge to understand."
}