{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The SPDR S&P 400 U.S. Mid Cap UCITS ETF (Acc) is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication, explicitly stating it seeks to hold all securities of the S&P MidCap 400 Index with approximate weightings. There is no mention of synthetic replication or swap agreements. 2. Derivative Usage: While the KIID mentions the fund 'may use financial derivative instruments... to manage the portfolio efficiently,' this is a standard disclosure for UCITS funds and does not indicate active derivative usage. The fact sheet confirms physical replication. 3. Leverage/Inverse: No references to leverage, inverse exposure, or amplified returns. 4. Underlying Assets: The fund invests in liquid, transparent mid-cap US equities with no mention of complex securities like CoCos or CLOs. 5. Risk Profile: The risk category (6) reflects historical volatility of mid-cap equities, not structural complexity. 6. Costs: Simple TER structure with no performance fees or complex fee arrangements. 7. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. The fact that the fund is physically replicated and tracks a straightforward equity index with no leverage or synthetic elements makes it suitable for retail investors.",
    "confidence": 95
}