{
    "fund_name": "Invesco FTSE 100 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"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication of the FTSE 100 Index, which introduces counterparty risk. While the underlying index (FTSE 100) is straightforward, the use of swaps and the synthetic replication method are key complexity indicators under MiFID II. The KIID explicitly mentions 'synthetic ETF risk' and 'counterparty risk' as material risks, which align with MiFID II's complexity criteria. The PRIIPs KID confirms the synthetic replication method and highlights counterparty risk as a significant factor. The fund's risk category (6/7) also suggests higher complexity. While the ETF tracks a simple index, the derivative-based replication method and counterparty exposure are sufficient to classify it as complex under MiFID II.",
    "confidence": 90
}