{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The iShares MSCI USA Leaders UCITS ETF USD (Dist) is a UCITS-compliant ETF that aims to replicate the MSCI USA Advanced Selection Index by physically holding the underlying equity securities in similar proportions. The fund uses derivatives only for direct investment purposes to produce a similar return to its index, but this use is limited and not integral to the investment objective, indicating derivatives are used for efficient portfolio management rather than as a core strategy. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products. Securities lending is employed as a secondary feature to generate income but is well-managed under UCITS rules with collateral requirements, and does not dominate the risk profile. The ETF does not use significant leverage beyond UCITS limits. The underlying index is transparent, based on large and mid-cap US companies with ESG criteria, and the ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for efficient portfolio management with minimal risk impact are classified as non-complex. The fund does not embed derivatives or complex features that would trigger a complex classification. Therefore, the ETF is classified as non-complex under MiFID II. This aligns with ESMA and CESR guidance that UCITS ETFs with physical replication and limited derivative use for EPM are non-complex, while synthetic or structured UCITS ETFs would be complex. No leverage, swaps, or embedded derivatives are present to increase complexity. The fund's risk profile reflects market risk, not structural complexity. Hence, no appropriateness test or comprehension alert is required for retail investors investing in this ETF."
}