{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Invesco Variable Rate Preferred Shares UCITS ETF is a UCITS-compliant, physically replicated ETF that aims to track the ICE Diversified Variable Rate Preferred & Hybrid Securities Index by holding the underlying securities in their respective weightings. There is no evidence of synthetic replication, significant derivative use (beyond efficient portfolio management, which is standard and does not trigger complexity under MiFID II for UCITS), leverage, swaps, or inverse strategies. The ETF may engage in securities lending, but this is a secondary feature, well-managed within UCITS rules, and does not dominate the risk profile. The underlying index consists of floating and variable rate preferred and hybrid securities, which are straightforward fixed income instruments without embedded derivatives or complex payout structures. The ETFu2019s structure, risks, and investment objective are transparent and can be readily understood by retail investors with basic knowledge. All UCITS are automatically non-complex under MiFID II unless they are structured UCITS or employ complex portfolio management techniques that make the risk profile difficult to understandu2014neither of which applies here[1][2]. The ETF does not hold contingent convertible bonds, complex indices, or other instruments that would introduce structural complexity or opacity. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 57 and the UCITS presumption[1][2]."
}