{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) to track the Solactive Fed Funds Effective Rate Total Return Index. While the index itself is relatively simple (tracking a cash deposit rate), the use of swaps introduces counterparty risk and derivative exposure, which are key complexity indicators under MiFID II. The KIID explicitly mentions risks associated with financial derivative instruments, including leverage risk, high volatility risk, and valuation risk. The fact that the ETF is UCITS-compliant does not negate the complexity introduced by the swap structure. The PRIIPs KID and factsheet confirm the synthetic replication method, reinforcing the complexity classification.",
    "confidence": 90
}