{
    "name": "AMUNDI S&P 500 UCITS ETF - USD (D)",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure"
    ],
    "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 factsheet confirms the synthetic replication method. While the underlying index (S&P 500) is straightforward, the use of swaps and the associated counterparty risk make this a complex instrument under MiFID II rules. The presence of liquidity risk and operational risk disclosures further supports this classification.",
    "confidence": 95,
    "risk_level": 4,
    "counter_argument": "The ETF tracks a well-known, liquid index (S&P 500) and is UCITS-compliant, which might suggest it is non-complex. However, the synthetic replication method and the explicit reliance on derivatives for performance tracking override this argument, as MiFID II considers such structures complex due to the additional risks (e.g., counterparty risk) and the need for investor understanding of these mechanisms.",
    "additional_notes": "The PRIIPs KID was not provided, but the KIID and factsheet clearly indicate synthetic replication and derivative usage, which are sufficient for a 'complex' classification. The ETF's risk level (SRRI 4) aligns with its synthetic structure, reinforcing the complexity determination."
}