{
    "fund_name": "UBS (Irl) ETF plc - UBS MSCI USA Universal UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": null,
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the MSCI USA Universal Low Carbon Select 5% Issuer Capped Index. It does not employ leverage, inverse strategies, or synthetic replication. While the KIID mentions that derivatives may be used, it specifies that they are for risk reduction rather than as a core part of the investment strategy. The risk category is 6 due to equity market volatility, not due to structural complexity. The fund is UCITS-compliant, has a straightforward investment objective, and maintains transparency in its holdings. The absence of complex features like leverage, inverse exposure, or synthetic replication supports the non-complex classification.",
    "confidence": 95,
    "counter_argument": "The mention of derivatives in the KIID could suggest potential complexity. However, the context clarifies that derivatives are used for risk management (e.g., hedging) rather than as a primary strategy, which aligns with standard ETF practices and does not introduce material complexity under MiFID II. The physical replication method and lack of leverage further reinforce the non-complex classification."
}