{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "OTC Swaps with counterparties"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is primarily physically replicated and tracks a straightforward US Treasury bond index, which would typically suggest a non-complex classification. However, the factsheet reveals the use of OTC swaps with counterparties (Morgan Stanley Bank AG and Societe Generale), which introduces counterparty risk and complexity. While the swap exposure is limited to 10% of the fund's assets as per UCITS guidelines, the presence of these derivatives for purposes beyond efficient portfolio management (EPM) triggers complexity under MiFID II. The counterparty risk, though mitigated, is a material factor that requires additional investor understanding. Additionally, the fund's use of sampling replication and the potential for tracking error further contribute to its classification as complex.",
    "confidence": 85,
    "risk_level": 3,
    "counterparty_risk": true,
    "tracking_error_risk": true,
    "liquidity_risk": false,
    "capital_protection": false,
    "structured_features": false,
    "illiquid_assets": false,
    "comprehension_warning": false
}