{
    "name": "AMUNDI FTSE EPRA NAREIT GLOBAL DEVELOPED - UCITS ETF DIST",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Total Return Swaps",
        "Counterparty Risk",
        "Indirect Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the swap structure creates a dependency on the swap counterparty's performance. While the ETF does not employ leverage or inverse strategies, the use of unfunded swaps and the associated counterparty risk make it complex under MiFID II rules. The risk profile (SRRI 4) and the presence of liquidity and operational risks further support this classification.",
    "confidence": 90,
    "counter_argument": "The ETF tracks a straightforward equity index (FTSE EPRA/NAREIT Developed) and does not use leverage or inverse strategies. The swap is used purely for replication, not for speculative purposes. However, the reliance on a derivative instrument (swap) and the associated counterparty risk outweigh these simpler aspects, as MiFID II explicitly flags synthetic replication as a complexity factor.",
    "risk_level": 4,
    "benchmark_complexity": "The underlying index (FTSE EPRA/NAREIT Developed) is a standard equity index with no inherent complexity, but the synthetic replication method introduces additional layers of risk."
}