{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Indirect replication (swap-based)",
        "Potential tracking error due to swap adjustments"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve exposure to the S&P 500 Index, which introduces counterparty risk and potential tracking error. While the fund does not use leverage or inverse strategies, the swap-based structure and counterparty risk exposure are key factors that trigger the 'complex' classification under MiFID II. The KIID and PRIIPs documents highlight the use of derivatives and counterparty risk, which are significant complexity indicators. The factsheet confirms the indirect replication method via swaps, reinforcing the synthetic nature of the fund. While the fund is UCITS-compliant and has a straightforward investment objective, the synthetic replication method and associated risks make it complex for retail investors to fully understand without specialist knowledge.",
    "confidence": 90
}