{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps with UBS AG as counterparty, which introduces counterparty risk. While the fund tracks a straightforward equity index (S&P 500 Equal Weight), the use of derivatives for replication rather than physical holding of securities triggers MiFID II complexity classification. The KIID and factsheet confirm the swap structure and collateral management, which are key complexity indicators. The risk profile (Category 6) and disclosures about counterparty risk further support this classification. The fact that it's UCITS-compliant doesn't override the complexity from derivative usage.",
    "confidence": 90
}