{
    "name": "UBS FTSE 100 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for replication",
        "Counterparty risk from OTC derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but explicitly states it may use derivatives, particularly when direct investment is impractical or to generate efficiencies. The KIID mentions OTC derivatives and counterparty risk, which are complexity indicators under MiFID II. While the fund is predominantly physically replicated, the documented use of derivatives for purposes beyond simple efficient portfolio management (EPM) and the explicit mention of counterparty risk from OTC derivatives push this into complex territory. The risk rating of 6 also suggests higher complexity.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication method and straightforward index-tracking objective. However, the explicit use of derivatives beyond EPM and the associated counterparty risks outweigh this argument.",
    "additional_notes": "The factsheet confirms physical replication as the primary method but does not negate the derivative usage mentioned in the KIID. The PRIIPs KID was not provided, but the KIID's risk disclosures and derivative usage are sufficient to classify this as complex under MiFID II."
}