{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "inverse": false,
    "derivatives": true,
    "swaps": true,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to track the Solactive Euro Overnight Return Index, which is based on the Euro Short Term Rate (ESTER) plus 0.085%. While the index itself is relatively straightforward, the use of swaps introduces counterparty risk and derivative exposure, which are key complexity indicators under MiFID II. The KIID explicitly mentions counterparty risk and derivative-related risks, which further supports the classification as complex. The fact that the ETF is UCITS-compliant does not negate the complexity introduced by the swap-based replication method. The risk profile is low (SRRI 1-2), but the use of derivatives for replication rather than just efficient portfolio management triggers the complexity classification.",
    "confidence": 90
}