{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex index methodology (momentum-based screening with multiple factors)",
        "Potential for tracking error (0-2% stated)",
        "High risk rating (6/7 on SRRI)"
    ],
    "classification": "non-complex",
    "supporting_data": "The First Trust US Momentum UCITS ETF uses physical replication to track the US Momentum iNDEX Index, which consists of 180 US equities selected based on momentum factors. The fund does not use derivatives, swaps, or leverage. While the index methodology is complex (involving multiple screening criteria and sector caps), the fund's straightforward physical replication approach and UCITS compliance suggest it is not complex under MiFID II. The high risk rating (6/7) reflects the underlying equity market exposure rather than structural complexity. The fact sheet confirms no derivative usage beyond efficient portfolio management, and the PRIIPs KID does not contain a comprehension warning. The primary complexity factors are the index construction and potential tracking error, but these do not meet MiFID II's complexity thresholds for classification.",
    "confidence": 90
}