{
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Complex underlying assets (Variable Rate Preferred & Hybrid Securities)",
        "Potential for issuer deferral of distributions (Preferred/Hybrid Securities Risk)",
        "Exposure to perpetual bonds without maturity dates",
        "High yield debt securities exposure",
        "Liquidity risk of underlying securities"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the ICE Diversified Variable Rate Preferred & Hybrid Securities Index, with no leverage, inverse exposure, or synthetic replication via swaps. The primary complexity factors stem from the underlying assets (variable rate preferred/hybrid securities) and their associated risks (issuer deferral, perpetual bonds, high yield exposure). However, these do not trigger MiFID II's 'complex' classification as the ETF remains transparent, liquid, and suitable for retail investors. The UCITS compliance and physical replication further support the non-complex determination.",
    "confidence": 90
}