{
    "fund_name": "First Trust Nasdaq Clean Edge Green Energy UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex index tracking (Nasdaq Clean Edge Green Energy IndexSM)",
        "Exposure to Chinese VIE structures (Variable Interest Entities)",
        "High risk profile (SRRI 7)"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the Nasdaq Clean Edge Green Energy IndexSM, which is a modified market capitalization weighted index of clean energy companies. There is no mention of synthetic replication, swaps, or leverage in the KIID or fact sheet. The fund invests directly in equity securities of the index constituents, with some use of depository receipts where direct investment is not possible. The risk profile is high (SRRI 7), but this is primarily due to the underlying equity market exposure rather than structural complexity. The main complexity factors are the potential risks associated with Chinese VIE structures and the complexity of the index itself, but these do not trigger a 'complex' classification under MiFID II. The fund is UCITS-compliant and has a straightforward investment objective of tracking the index.",
    "confidence": 90,
    "counter_argument": "The high SRRI (7) and exposure to Chinese VIE structures could be seen as indicators of complexity. However, the fund's physical replication method, lack of derivatives or leverage, and transparent index-tracking strategy outweigh these factors in the MiFID II complexity assessment. The risks are market risks rather than structural risks, and the fund's structure is straightforward and suitable for retail investors.",
    "overriding_reason": "The absence of derivatives, leverage, or synthetic replication, combined with the fund's physical replication method and transparent index-tracking strategy, lead to a 'non-complex' classification despite the high risk profile and exposure to VIE structures."
}