{
    "fund_name": "AMUNDI S&P 500 BUYBACK UCITS ETF - EUR",
    "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 total return swaps to track the S&P 500 Buyback Index, which introduces counterparty risk and derivative exposure. While the fund itself is not leveraged or inverse, the use of swaps for replication (rather than physical holdings) and the associated counterparty risk are key factors that trigger the 'complex' classification under MiFID II. The KIID explicitly mentions that derivatives are 'integral to the Sub-Fund's investment strategy' and highlights counterparty risk as a material risk. The fact that the ETF is UCITS-compliant does not automatically exempt it from being classified as complex, as UCITS rules allow for synthetic replication with derivatives. The risk profile (SRRI 4) and the disclosure of counterparty risk further support the complex classification.",
    "confidence": 90
}