{
    "name": "Xtrackers II EUR Overnight Rate Swap UCITS ETF",
    "isin": "LU0335044896",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Derivative Exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the Solactive EURSTR +8.5 Daily Total Return Index, which introduces counterparty risk and derivative exposure. The KIID explicitly mentions the use of derivatives and swap agreements, which are key indicators of complexity under MiFID II. Additionally, the fund's performance is dependent on the counterparties' ability to meet their obligations, adding another layer of risk that retail investors may not fully understand. The presence of counterparty risk and the reliance on derivatives for replication make this ETF complex, even though it does not employ leverage or inverse strategies.",
    "confidence": 90,
    "risk_level": 1,
    "counterparty_risk": true,
    "underlying_assets": "Interest rate derivatives and swaps",
    "benchmark_complexity": "The benchmark is relatively simple as it tracks a deposit rate with a fixed spread, but the synthetic replication method adds complexity."
}