{
    "fund_name": "Amundi Stoxx Europe Select Dividend 30 - UCITS ETF DIST A",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "inverse": false,
    "derivatives": true,
    "swaps": true,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which is a key complexity indicator under MiFID II. While the underlying index (STOXX Europe Select Dividend 30) appears straightforward (equity-focused, dividend-paying European companies), the use of swaps introduces counterparty risk and potential tracking error, making it complex. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and highlights counterparty risk, which are red flags for complexity. The fact that it's UCITS-compliant does not negate the complexity due to the swap-based structure. The PRIIPs KID and factsheet confirm the synthetic replication method, reinforcing the classification.",
    "confidence": 90,
    "counter_argument": "One might argue that the underlying index is simple (equity-focused, dividend-paying stocks) and the swap is used for efficient replication rather than leverage or exotic strategies. However, MiFID II explicitly flags synthetic replication via swaps as a complexity factor, regardless of the underlying asset class. The presence of counterparty risk and the explicit mention of derivatives in the KIID override any simplicity in the index.",
    "risk_profile_alignment": "The risk profile (SRRI 3) is moderate, but the complexity arises from the replication method, not the underlying assets. The counterparty risk and potential tracking error from the swap structure are not reflected in the SRRI, which focuses on market risk."
}