{
    "fund_name": "RIZE CYBERSECURITY AND DATA PRIVACY UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for non-EPM purposes",
        "Thematic index complexity"
    ],
    "classification": "complex",
    "supporting_data": "The KIID and factsheet indicate that while the ETF primarily uses physical replication, it may also invest in financial derivative instruments (FDIs) based on the index constituents. Although the derivatives are not used for leverage or synthetic replication, their inclusion introduces additional complexity beyond simple physical replication. The thematic nature of the Foxberry Tematica Research Cybersecurity & Data Privacy Index, which involves proprietary scoring and liquidity adjustments, adds another layer of complexity. The risk rating of 7 and the potential for significant tracking error due to the thematic approach further support the complex classification.",
    "confidence": 85,
    "risk_level": 7,
    "counter_argument": "The ETF could be argued as non-complex due to its primary use of physical replication and lack of leverage or synthetic exposure. However, the potential use of derivatives beyond efficient portfolio management (EPM) and the complexity of the underlying thematic index justify the complex classification under MiFID II.",
    "additional_notes": "The PRIIPs KID was not provided, but the KIID and factsheet sufficiently indicate the potential complexity due to derivative usage and the specialized nature of the index. The ETF's UCITS compliance does not override the MiFID II complexity assessment, as UCITS funds can still be classified as complex if they meet certain criteria."
}