{
    "name": "Xtrackers MSCI India Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure",
        "Emerging market complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swap agreements to track the MSCI India TRN Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions derivative usage and counterparty risk as significant factors. While the fund does not employ leverage or inverse strategies, the reliance on swaps for replication and exposure to emerging market risks (India) contributes to its complexity. The risk profile is rated at level 6, indicating high volatility. The factsheet confirms indirect replication (swap) methodology and highlights counterparty risk as a key concern.",
    "confidence": 90,
    "counter_argument": "Some might argue that swap-based ETFs are common and well-understood, thus not inherently complex. However, MiFID II explicitly flags synthetic replication and counterparty risk as complexity indicators, overriding this argument.",
    "risk_level": 6
}