{
    "fund_name": "Amundi Euro Government Bond 7-10Y UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Securities Lending"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication to track the Bloomberg Barclays Euro Treasury 50bn 7-10 Year Bond Index. However, the factsheet reveals the use of OTC swaps with counterparties (Morgan Stanley Bank AG, Societe Generale) and securities lending, which introduces counterparty risk. While the swap exposure is limited to 10% of total assets per UCITS guidelines, the presence of these derivative instruments and the associated counterparty risk elevate the complexity. The ETF is UCITS-compliant and has a straightforward investment objective, but the use of swaps and securities lending, even if limited, introduces elements that may not be easily understood by retail investors. The risk of counterparty default and the operational risks associated with swaps and securities lending are material factors in this classification.",
    "confidence": 85,
    "risk_level": 3,
    "counterparty_risk": true,
    "securities_lending": true,
    "benchmark_complexity": "low",
    "liquidity_risk": "low",
    "capital_protection": false,
    "structured_features": false,
    "primary_reasoning": "The use of OTC swaps and securities lending introduces counterparty risk and operational complexity, which are not fully mitigated by the UCITS compliance and physical replication. These factors make the ETF complex under MiFID II, despite its otherwise straightforward bond index-tracking objective."
}