{
    "name": "UBS (Lux) Fund Solutions - Bloomberg TIPS 1-10 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivatives for index replication",
        "Counterparty risk from OTC derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives, including OTC derivatives, to replicate the index when direct investment is not possible or practicable. This introduces counterparty risk, which is a key complexity indicator under MiFID II. While the primary replication method is physical, the use of derivatives for replication purposes and the associated counterparty risk exposure make this a complex instrument. The KIID explicitly mentions the use of derivatives and the risks associated with counterparty exposure, which are not typical features of non-complex instruments.",
    "confidence": 85,
    "risk_level": 3,
    "additional_notes": "Although the ETF is UCITS-compliant and primarily uses physical replication, the use of derivatives for index replication and the associated counterparty risk exposure are sufficient to classify it as complex under MiFID II. The PRIIPs KID and factsheet do not introduce additional complexity factors beyond what is already disclosed in the KIID."
}