{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Currency hedging via derivatives",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via over-the-counter swap contracts (FDI) to track the S&P 500 Index, which introduces counterparty risk. While the fund does not use leverage or inverse strategies, the use of derivatives for replication and currency hedging makes it complex under MiFID II. The KIID explicitly mentions financial derivative instruments and counterparty risk, which are key complexity indicators. The fact sheet confirms the synthetic replication method. While the underlying index (S&P 500) is straightforward, the derivative-based replication structure and currency hedging mechanism elevate the complexity beyond what would be considered simple for retail investors.",
    "confidence": 90
}