{
    "fund_name": "Invesco STOXX Europe 600 Optimised Media UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and requires understanding of derivative mechanics. The STOXX Europe 600 Optimised Media Index applies complex liquidity weighting and sector caps, adding to the product's complexity. While the fund has a straightforward equity exposure, the synthetic structure and derivative reliance make it complex under MiFID II. The PRIIPs KID confirms the synthetic replication method and highlights counterparty risk as a key consideration.",
    "confidence": 90,
    "risk_level": "6 (high)",
    "counter_argument": "The fund tracks a simple equity index and has no leverage, which could suggest non-complex status. However, the synthetic replication method and derivative usage override this, as MiFID II prioritizes the replication method over the underlying asset class.",
    "overriding_reason": "The use of unfunded swaps and synthetic replication creates material complexity that outweighs the simplicity of the underlying equity exposure. MiFID II guidelines explicitly consider replication method as a primary complexity factor."
}