{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for investment purposes, quantitative investment process, securities lending, no benchmark tracking",
    "classification": "complex",
    "supporting_data": "The HSBC PLUS World Equity Income Quant Active UCITS ETF is a UCITS-compliant, actively managed ETF that does not track a benchmark. It may use derivatives for both efficient portfolio management and investment purposes, and may engage in securities lending up to 30% of assets. The fund applies a quantitative investment process focusing on risk premia from factors such as value, quality, momentum, low risk, and size. While UCITS ETFs are generally presumed non-complex under MiFID II, this presumption is overturned if the ETF's structure, risks, or payoff are difficult for retail investors with basic knowledge to understand. The active use of derivatives for investment purposes (not just hedging or efficient portfolio management) and the quantitative, factor-based strategy introduce complexity beyond the standard UCITS ETF. The fund's KIID explicitly lists 'Derivatives Risk' and 'Investment Leverage Risk' as material risks, indicating that derivatives are integral to the investment strategy, not merely ancillary. This level of complexity, combined with active management and a non-benchmark-tracking approach, means the fund's structure and risks are not easily understood by the average retail investor, triggering a complex classification under MiFID II Article 57 criteria[1][3]. Securities lending, while common and not automatically complex, is noted but does not drive the classification. The fund's high risk rating (6/7) reflects market risk, not structural complexity, but the use of derivatives for investment purposes is decisive. Therefore, despite being a UCITS ETF, this fund is complex due to its active management, derivative usage for investment (not just EPM), and quantitative strategy."
}