{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure from swap agreements",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the S&P 500 Index, which introduces counterparty risk and makes the investment strategy more complex than physical replication. While the underlying index (S&P 500) is relatively straightforward, the use of derivatives for replication purposes triggers MiFID II complexity classification. The KIID explicitly mentions that derivatives are integral to the Sub-Fund's investment strategy, and the fact sheet confirms synthetic replication. The risk profile includes counterparty risk, which is a key complexity indicator. The ETF is UCITS-compliant, but this does not override the complexity determination based on derivative usage. The absence of leverage or inverse exposure means the complexity is primarily driven by the synthetic structure rather than amplified risk.",
    "confidence": 90
}