{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives used for risk management, not central to strategy; no embedded derivatives, no leverage, no complex indices, no contingent convertible bonds, no swaps, no inverse structure",
    "classification": "non-complex",
    "supporting_data": "The UBS Core S&P 500 UCITS ETF is a UCITS-compliant, physically replicated ETF tracking the S&P 500 Index. It may use derivatives for efficient portfolio management (EPM), such as hedging currency risk, but derivatives are not central to its investment objective. The ETF does not use synthetic replication, leverage beyond UCITS limits, embedded derivatives, swaps, or inverse strategies. The index tracked is transparent and well-established. Securities lending is permitted but is a secondary activity, managed within UCITS rules. The risk profile reflects equity market volatility, not structural complexity. All these features are consistent with the UCITS presumption of non-complexity under MiFID II, as the structure, risks, and objectives are straightforward and understandable for retail investors with basic knowledge[1]. The use of derivatives for EPM with minimal impact on the risk-return profile does not, in this case, trigger a complex classification, as the derivatives are not integral to the ETF's strategy and do not introduce material counterparty or collateral risk that would be difficult for a retail investor to understand. There is no evidence of complex indices, contingent convertible bonds, or other features that would override the UCITS non-complex presumption."
}