{
    "fund_name": "HSBC FTSE EPRA NAREIT DEVELOPED UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "inverse": false,
    "derivatives": true,
    "swaps": true,
    "complex_factors": [
        "Use of total return swaps (up to 10%)",
        "Potential for counterparty risk from derivatives",
        "Complexity of underlying real estate index"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication (as confirmed in the fact sheet) with derivatives (including swaps) used for efficient portfolio management rather than as an inherent part of the strategy. The swap usage is limited to 10% of assets (not expected to exceed 5%), which is within typical EPM (Efficient Portfolio Management) parameters. The underlying index (FTSE EPRA NAREIT Developed) consists of large, liquid real estate companies and REITs, which are relatively straightforward. While there is some complexity from derivative usage and counterparty risk, this does not rise to the level of making the product 'complex' under MiFID II, as the derivatives are used for risk management and cost efficiency rather than as a core investment strategy. The fact that the ETF is UCITS-compliant and tracks a transparent, liquid index further supports the non-complex classification.",
    "confidence": 85
}