{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication with swaps",
        "Complex index with buffer/cap mechanism",
        "Derivative-based risk management"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via unfunded swaps with counterparty risk, tracks a complex index with buffer/cap features requiring options strategies, and employs derivative-based risk management. While UCITS-compliant, the combination of synthetic replication and structured index characteristics makes it complex under MiFID II. The PRIIPs KID would likely contain a comprehension warning, further supporting this classification.",
    "confidence": 90
}