{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF (UBS MSCI USA Select Factor Mix UCITS ETF) which is by default presumed non-complex under MiFID II Article 25(4)(a)(iv) and related regulations. The ETF uses a sampling strategy with portfolio optimization to track the MSCI USA Select Factor Mix Index, which is a transparent equity index. The ETF may use derivatives only for risk reduction, cost reduction, or income generation, but this use is limited and for efficient portfolio management (EPM) purposes, not integral to the investment objective. The KID explicitly states that the Fund will not enter into securities lending, and there is no mention of leverage beyond UCITS limits. The replication method is physical (sampling of underlying stocks), not synthetic. The risk profile is high due to equity market volatility but this does not imply structural complexity. The ETF does not embed derivatives or structured products such as CLOs. According to ESMA and CESR guidance, UCITS ETFs that do not use synthetic replication or embedded derivatives and that use derivatives only for EPM with minimal impact on risk-return are classified as non-complex. Therefore, this ETF meets the criteria for non-complex classification under MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57. No complex features such as embedded derivatives, leverage, synthetic replication, or opaque index structures are present. Hence, no appropriateness assessment is required for execution-only sales to retail investors."
}