{
    "name": "Invesco EQQQ NASDAQ-100 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco EQQQ NASDAQ-100 UCITS ETF is a physically replicated ETF that tracks the NASDAQ-100 Index. It uses direct investment in the underlying securities to achieve its objective, with no evidence of leverage, inverse strategies, or synthetic replication. The fund employs currency hedging via FX forwards to manage currency risk, which is a standard practice for UCITS-compliant funds and does not introduce complexity under MiFID II. The risk profile is clearly disclosed (risk category 6), and the fund's structure is transparent, with no indications of illiquid or hard-to-value assets. The use of securities lending is disclosed but does not introduce complexity as it is a common practice in ETFs. The fund's performance is closely aligned with its benchmark, and there are no capital protection mechanisms or structured features. The ongoing charge is straightforward (0.35%), and there are no performance fees or complex cost structures.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of FX forwards for currency hedging could introduce complexity. However, FX forwards are a standard tool for managing currency risk in UCITS ETFs and are not considered complex under MiFID II when used for this purpose. Additionally, the fund's physical replication method and transparent structure outweigh any minor complexity introduced by hedging.",
    "risk_level": 6
}