{
    "fund_name": "Invesco S&P 500 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivative instruments. The KIID explicitly states the use of swap agreements to exchange the performance of securities held by the fund for the performance of the S&P 500 Index. Additionally, the fund's risk category is 6, indicating higher risk, and the presence of synthetic replication and derivative-related risks further supports the classification as complex. The PRIIPs document reinforces the use of swaps and the reliance on counterparties, which are key indicators of complexity under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "comprehension_warning": false,
    "benchmark_complexity": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of synthetic replication via swaps and the associated counterparty risks are sufficient to classify it as complex under MiFID II. The fund's structure requires investors to understand the implications of swap agreements and counterparty exposure, which are not straightforward and introduce additional layers of risk."
}