{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which is automatically classified as non-complex under MiFID II Article 25(4)(a)(iv) unless it is a structured UCITS or uses derivatives as a central part of its investment strategy[1]. This ETF tracks a transparent, alternatively weighted equity index (MSCI USA Select Factor Mix) using physical replication via a sampling/optimization strategy, not synthetic replication or swaps. While the fund may use derivatives for efficient portfolio management (EPM) such as currency hedging, this use is ancillary, limited in scope, and not central to the fund's investment objective. There is no securities lending, no significant leverage beyond UCITS limits, and no embedded derivatives or complex payout structures. The risks disclosed (high equity volatility, currency risk) are standard for equity ETFs and do not introduce structural complexity. The fund's structure, objective, and risks are transparent and can be understood by a retail investor with basic knowledge. Therefore, it meets all criteria for non-complex classification under MiFID II and does not require an appropriateness test for execution-only transactions[1]."
}