{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Invests primarily in residential mortgage-backed securities (RMBS), including agency and non-agency MBS, which are securitized debt instruments with embedded risks; active management approach involving bottom-up analysis of collateral and capital structure; exposure to credit risk, prepayment risk, and liquidity risk inherent in RMBS; no indication of synthetic replication or embedded derivatives in the ETF structure; no leverage beyond UCITS limits; no capital protection features; transparent underlying index not specified but likely straightforward fixed income indices; derivatives use appears limited to portfolio management rather than integral to replication.",
    "classification": "complex",
    "supporting_data": "The fund is a UCITS ETF investing at least 80% in RMBS, which are securitized debt instruments subject to credit risk, prepayment risk, and liquidity risk. RMBS, especially non-agency and subprime sectors, are complex fixed income securities with embedded risks that are difficult for retail investors with basic knowledge to fully understand. The fund employs active management analyzing collateral and capital structure, indicating complexity beyond simple index tracking. Although the ETF uses physical replication and does not appear to use synthetic replication or embedded derivatives as part of its replication method, the underlying assets themselves (RMBS) are complex securitized products often considered complex under MiFID II due to their structure and risk profile. The fund does not use significant leverage or capital protection, and derivatives use is likely limited to efficient portfolio management, but the complexity arises mainly from the nature of the underlying RMBS holdings. According to MiFID II and ESMA guidelines, securitized debt instruments embedding derivatives or with complex structures are classified as complex. Therefore, despite being a UCITS ETF, the fund's investment in complex RMBS leads to a complex classification under MiFID II appropriateness rules."
}