{
    "fund_name": "Invesco FTSE 250 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, which introduces counterparty risk and requires understanding of derivative mechanics. While the underlying index (FTSE 250) is straightforward, the swap-based structure and potential tracking error make this a complex product under MiFID II. The PRIIPs KID confirms synthetic replication and swap usage, while the fact sheet highlights counterparty risk as a material consideration. The risk category 6 (out of 7) further supports the complexity classification.",
    "confidence": 90,
    "counter_argument": "One could argue that since the ETF tracks a simple equity index and has no leverage, it should be non-complex. However, the synthetic replication via swaps and associated counterparty risk override this argument under MiFID II's complexity criteria.",
    "risk_profile_alignment": "The risk category 6 aligns with the complexity classification, as synthetic ETFs inherently carry higher risks than physically replicated funds due to counterparty and tracking error risks."
}