{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Complex index with buffer/cap mechanisms",
        "Derivative-based risk management"
    ],
    "classification": "complex",
    "supporting_data": "The fund uses synthetic replication via unfunded swaps with counterparty risk, tracks a complex index with buffer/cap mechanisms (S&P 500 Annual 30% (-5% to -35%) Buffer Protect Index), and employs derivative strategies (put/call options) that require specialized knowledge. While not leveraged, the derivative-based risk management and structured index make this complex under MiFID II. The PRIIPs KID may contain additional complexity warnings, and the factsheet would confirm swap usage details.",
    "confidence": 90
}