{
    "name": "HSBC USA SCREENED EQUITY UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for investment purposes",
        "Total return swaps",
        "Contracts for difference"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but has provisions to use derivatives, including total return swaps and contracts for difference, for investment purposes beyond just efficient portfolio management. The KIID explicitly states that the fund may invest up to 10% in total return swaps and contracts for difference, which introduces counterparty risk and potential complexity in understanding the fund's performance drivers. Additionally, the risk disclosures highlight derivative risk and investment leverage risk, which are indicators of complexity under MiFID II. While the fund is UCITS compliant and has a straightforward investment objective, the potential use of derivatives for investment purposes (not just EPM) and the explicit mention of swap agreements make it a complex instrument.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "tracking_error_risk": true,
    "esg_focus": true,
    "benchmark_complexity": "low",
    "additional_notes": "Although the ETF is primarily physically replicated, the allowance for using derivatives for investment purposes (not just EPM) and the explicit mention of swap agreements in the KIID trigger the complexity classification under MiFID II. The fund's risk level of 6 and the presence of counterparty risk further support this classification."
}