{
    "name": "iShares Developed Markets Property Yield UCITS ETF USD (Acc)",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Use of derivatives for direct investment purposes",
        "Counterparty risk from derivative usage"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses financial derivative instruments (FDIs) for direct investment purposes, which introduces complexity beyond simple physical replication. While the primary replication method is physical, the use of derivatives for direct investment (not just efficient portfolio management) and the explicit mention of counterparty risk in the risk disclosures suggest additional complexity. The risk rating of 6 out of 7 also indicates higher complexity. The presence of derivative usage for purposes other than efficient portfolio management (EPM) and the associated counterparty risks are the primary drivers for the complex classification.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication method and lack of leverage or inverse exposure. However, the use of derivatives for direct investment purposes and the explicit counterparty risk warnings override this argument, as MiFID II considers such features to introduce complexity that may not be easily understood by retail investors."
}