{
    "name": "Amundi Corporate Proceeds Bond UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Complex Indices"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex due to the use of swaps and counterparty risk exposure, despite primarily using physical replication. The factsheet explicitly mentions counterparty risk from OTC swaps with Morgan Stanley Bank AG and Societe Generale, which introduces complexity. Additionally, the underlying index (Solactive EUR USD IG Corporate Green Bond TR Index) involves ESG screening and specific criteria that may not be easily understood by retail investors. The presence of financial derivatives (futures) and the potential for tracking error further contribute to the complexity. While the ETF is UCITS compliant and uses physical replication, the swap agreements and counterparty risks are significant enough to warrant a complex classification under MiFID II.",
    "confidence": 85,
    "risk_level": 4,
    "counter_argument": "The ETF could be argued as non-complex due to its physical replication strategy and straightforward investment in corporate green bonds. However, the use of swaps and the associated counterparty risks, as well as the complexity of the underlying index, override this argument. The MiFID II guidelines emphasize that any significant counterparty risk or derivative usage, even in a physically replicated ETF, can lead to a complex classification."
}