{
    "name": "Invesco NASDAQ-100 Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to replicate the NASDAQ-100 Index, which introduces counterparty risk and complexity. The KIID explicitly mentions the reliance on swap agreements and the potential financial loss due to counterparty insolvency. The risk category is 6, indicating higher risk. The synthetic replication method and the use of derivatives for index tracking are key factors in classifying this ETF as complex under MiFID II.",
    "confidence": 95,
    "counter_argument": "The ETF is UCITS-compliant and has a straightforward objective of tracking the NASDAQ-100 Index. However, the use of swaps and the associated counterparty risk outweigh these factors, making it complex under MiFID II.",
    "risk_level": 6,
    "additional_notes": "The ETF's risk profile and the use of synthetic replication via swaps are the primary reasons for its classification as complex. The presence of a 'comprehension warning' in the PRIIPs document would further support this classification, though it is not explicitly mentioned in the provided documents."
}