{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers S&P 500 Swap UCITS ETF uses synthetic replication via swap agreements to track the S&P 500 Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the use of derivatives and swap counterparties, which are key indicators of complexity under MiFID II. While the fund does not employ leverage or inverse strategies, the reliance on swaps and the associated counterparty risk make it a complex instrument. The risk level is classified as category 6, indicating high potential for price fluctuations, further supporting the complex classification. The fund's documentation highlights risks such as tracking error, counterparty risk, and the potential for losses due to derivative adjustments, all of which contribute to its complexity.",
    "confidence": 90
}