{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives for efficient portfolio management and index tracking, limited use of total return swaps and contracts for difference, securities lending",
    "classification": "non-complex",
    "supporting_data": "This UCITS ETF is physically replicating the MSCI USA Index, holding the underlying securities in generally the same proportion as the index. While the fund may use derivatives for efficient portfolio management (EPM) and, in limited circumstances, for index tracking (up to 10% in total return swaps and contracts for difference, not expected to exceed 5%), this use is ancillary and not central to the investment strategy. The fund may engage in securities lending (up to 30% of assets, not expected to exceed 25%), which is a common, well-disclosed feature in UCITS ETFs and does not, by itself, make the product complex. The structure, risks, and investment objective are transparent and straightforward for a retail investor with basic knowledge. There is no significant leverage, no embedded derivatives, and no complex or opaque features. The UCITS regulatory framework ensures high standards of liquidity, diversification, and investor protection, supporting the non-complex classification[1]. The use of derivatives is limited to risk and cost management, not for speculative purposes or to achieve leveraged or inverse returns. The risks disclosed (e.g., derivatives risk, counterparty risk, liquidity risk) are typical for physically replicated equity ETFs and do not introduce structural complexity that would be difficult for a retail investor to understand. Therefore, despite some derivative usage, the ETF remains non-complex under MiFID II, as the derivative exposure is not integral to the fund's objective and does not materially alter the risk-return profile in a way that would require an appropriateness test for retail distribution[1]."
}