{
    "fund_name": "UBS Factor MSCI USA Quality Screened UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "inverse": false,
    "derivatives": true,
    "swaps": true,
    "complex_factors": [
        "Synthetic replication",
        "Currency hedging via derivatives",
        "Potential counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through derivatives (including swaps) for currency hedging and potentially for index replication. While it doesn't use leverage or inverse strategies, the use of derivatives for replication and hedging introduces counterparty risk and complexity beyond simple physical replication. The risk profile is rated 6/7, indicating high volatility, and the KIID mentions derivative-related risks explicitly. The PRIIPs KID (if available) would likely contain a comprehension warning, further supporting the complex classification.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant and uses derivatives primarily for efficient portfolio management (currency hedging and potential synthetic replication). The underlying index is a standard equity index, and the fund doesn't use leverage or inverse strategies. Some might argue this should be classified as non-complex.",
    "overriding_reason": "MiFID II guidance specifies that synthetic replication using derivatives (even for hedging) typically triggers a complex classification, regardless of leverage or inverse exposure. The explicit mention of counterparty risk and derivative-related risks in the KIID further supports this."
}