{
    "fund_name": "UBS (Irl) ETF plc - MSCI USA UCITS ETF (hedged to GBP) A-acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the MSCI USA 100% hedged to GBP Index, holding the underlying securities directly. While derivatives are mentioned for risk reduction, cost efficiency, or income generation, they are not used for leverage or synthetic replication. The risk profile (category 6) is due to equity market volatility rather than structural complexity. The KIID and factsheet confirm no leverage, inverse strategies, or complex underlying assets. The use of derivatives is limited to efficient portfolio management (EPM) and hedging, which does not trigger complexity under MiFID II.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives for hedging or income generation could introduce complexity. However, under MiFID II, derivatives used solely for EPM or hedging purposes do not classify an ETF as complex, provided they do not materially alter the risk profile or require specialist knowledge. The ETF's straightforward physical replication and transparent index-tracking objective support the non-complex classification.",
    "risk_level": 6,
    "risk_explanation": "The risk level is high due to equity market volatility, not structural complexity. The ETF is passively managed and directly dependent on the performance of its underlying equities, which is typical for non-complex ETFs."
}