{
    "fund_name": "iShares US Mortgage Backed Securities UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for investment purposes",
        "Mortgage-backed securities complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses financial derivative instruments (FDIs) for direct investment purposes, not solely for efficient portfolio management (EPM). The KIID explicitly states that FDIs may be used for direct investment, which goes beyond simple hedging or replication. Additionally, the underlying assets (mortgage-backed securities) introduce complexity due to their structured nature, prepayment risks, and sensitivity to interest rate changes. While the replication method is physical, the use of derivatives for investment purposes and the inherent complexity of MBS justify the 'complex' classification under MiFID II.",
    "confidence": 85,
    "risk_level": 4,
    "counter_argument": "The ETF could be argued as non-complex due to its UCITS compliance, physical replication, and lack of leverage or inverse strategies. However, the explicit mention of derivatives for direct investment purposes and the complexity of mortgage-backed securities outweigh these factors, leading to a 'complex' classification."
}