{
    "fund_name": "First Trust United Kingdom AlphaDEX UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the NASDAQ AlphaDEX United Kingdom Index, which is a modified equally-weighted index based on fundamental growth and value factors. The fund invests primarily in equity securities included in the index, with minimal use of derivatives (only for depositary receipts where direct investment is not possible). There is no leverage, inverse exposure, or synthetic replication. The risk profile is rated 6/7, but this is typical for equity funds and does not indicate complexity. The fund is UCITS-compliant, and the replication method is straightforward (physical - full replication). The underlying index is transparent and based on a clear methodology. The fund's charges are simple (0.65% ongoing charges), and there are no performance fees or complex fee structures. The fund does not hold complex assets like contingent convertible bonds or structured products. The PRIIPs KID and fact sheet confirm the physical replication method and lack of derivative usage beyond minimal EPM (efficient portfolio management).",
    "confidence": 95,
    "counter_argument": "One could argue that the AlphaDEX methodology introduces complexity due to its fundamental growth and value factor selection process. However, this is inherent to the index and does not make the ETF itself complex under MiFID II, as the fund simply tracks the index without additional layers of complexity. The use of depositary receipts is minimal and does not trigger complexity.",
    "overriding_reason": "The fund's physical replication, lack of derivatives beyond minimal EPM, and transparent index-tracking strategy align with MiFID II's criteria for non-complex instruments. The AlphaDEX methodology is part of the index and does not introduce complexity at the fund level."
}