{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complexity of underlying index (S&P 500)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps with UBS as counterparty, which introduces counterparty risk. While the S&P 500 is a well-known index, the use of derivatives for replication and the associated counterparty risk make this product complex under MiFID II. The PRIIPs KID and fact sheet confirm the synthetic replication method and swap usage. The fact that the fund is UCITS-compliant does not automatically make it non-complex, as UCITS rules allow for certain derivative usage that may still trigger MiFID II complexity classification. The risk profile (category 6) and the extensive counterparty risk disclosures further support this classification.",
    "confidence": 90
}