{
    "fund_name": "WisdomTree AT1 CoCo Bond UCITS ETF - USD Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Contingent Convertible Bonds (CoCos)",
        "Complex underlying assets"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to Contingent Convertible Bonds (CoCos), which are inherently complex instruments with features such as principal write-downs, discretionary coupons, and potential conversion into equity under certain conditions. The KIID explicitly states that CoCos are 'relatively new and complex instruments' and highlights risks such as regulatory capital ratio triggers, non-viability clauses, and untested behavior in stressed financial environments. Additionally, the ETF's investment in AT1 CoCos, which are perpetual instruments with no stated maturity and discretionary coupons, introduces significant complexity. While the ETF uses physical replication and does not employ leverage or derivatives for investment purposes, the underlying assets (CoCos) are sufficiently complex to warrant a 'complex' classification under MiFID II. The risk profile (SRRI 6) and extensive risk disclosures further support this classification.",
    "confidence": 90,
    "counter_argument": "Some might argue that the ETF is non-complex because it uses physical replication and does not employ leverage or derivatives for investment purposes. However, the complexity of the underlying CoCos, their regulatory triggers, and the potential for principal write-downs or conversion into equity outweigh these factors, making the ETF complex under MiFID II rules.",
    "risk_level": 6
}