{
    "fund_name": "HSBC MSCI INDONESIA UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Emerging market exposure",
        "Concentration risk (top 3 holdings represent ~60% of the fund)",
        "Potential for up to 10% in total return swaps (though not expected to exceed 5%)"
    ],
    "classification": "non-complex",
    "supporting_data": "The fund primarily uses physical replication to track the MSCI Indonesia Index, with no leverage or inverse exposure. While it has permission to use up to 10% of assets in total return swaps (not expected to exceed 5%), this appears to be for efficient portfolio management rather than as a core strategy. The main complexity factors are the emerging market exposure and concentration risk, but these are typical of country-specific equity ETFs and don't trigger MiFID II complexity classification. The fund's risk profile is clearly disclosed and aligns with its straightforward equity tracking objective.",
    "confidence": 90,
    "counter_argument": "One could argue that the permission to use swaps (even if not expected to exceed 5%) makes this complex, but the fact that the fund is physically replicated and the swap usage appears limited to EPM purposes (efficient portfolio management) supports the non-complex classification. The monthly fact sheet confirms physical replication as the primary method.",
    "risk_level": "7 (as stated in KIID, reflecting emerging market volatility)"
}