{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Collateralized Loan Obligations (CLOs)",
        "Structured credit risk",
        "Liquidity risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily invests in AAA-rated Collateralized Loan Obligations (CLOs), which are inherently complex structured credit instruments. While the fund does not use leverage, inverse strategies, or synthetic replication, the underlying assets (CLOs) introduce significant complexity due to their tranched structure, credit risk, and liquidity challenges. The KIID explicitly states that the product 'is not simple and may be difficult to understand,' which aligns with MiFID II's definition of a complex instrument. The risk profile (rated 3) and extensive disclosures about CLO-specific risks (credit, liquidity, prepayment, and manager dependence) further support this classification. Although derivatives are only used for hedging purposes, the complexity arises from the nature of the underlying assets rather than the fund's structure.",
    "confidence": 90
}