{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - UBS Factor MSCI USA Prime Value Screened UCITS ETF is classified as non-complex under MiFID II based on the following analysis:1. **Replication Method**: The fund uses physical replication (as confirmed in the factsheet) with 'full replication' of the MSCI USA Prime Value ESG Low Carbon Select 100% Hedged to GBP Index. This is a non-complex indicator.2. **Derivative Usage**: While the KIID mentions potential use of derivatives for 'efficiencies in gaining exposure to the index' and currency hedging, the factsheet explicitly states 'Physical (Full replicated)' with no mention of synthetic replication or swaps. The derivatives mentioned are for hedging currency risk (selling foreign currency forwards at one-month forward rates), which is a standard practice in many ETFs and does not trigger complexity under MiFID II.3. **Risk Profile**: The fund is in risk category 6 (high volatility), but this is typical for equity ETFs and does not indicate complexity. The risks are clearly disclosed and relate to equity market volatility, not derivative-specific risks.4. **Underlying Assets**: The fund invests in large/mid-cap US equities with ESG screening, which are transparent and liquid assets. There is no exposure to complex instruments like contingent convertible bonds or structured products.5. **Counterparty Risk**: The KIID mentions counterparty risk from derivatives, but this is mitigated by UBS's collateral policy. The factsheet does not mention any swap counterparty exposure, further supporting the non-complex classification.6. **Costs**: The TER is 0.28%, with no performance fees or complex fee structures. The costs are straightforward and do not indicate complexity.7. **UCITS Compliance**: The fund is UCITS-compliant, which inherently limits the use of complex strategies and derivatives.8. **Index Complexity**: The MSCI USA Prime Value ESG Low Carbon Select Index is a standard equity index with a currency hedge, which is not considered complex under MiFID II.The only potential complexity factor is the currency hedging via derivatives, but this is a common practice in many ETFs and does not trigger a complex classification under MiFID II. The overall structure is transparent, with no leverage, inverse exposure, or complex underlying assets.",
    "confidence": 90
}