{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The JPM USD Ultra-Short Income Active UCITS ETF is a UCITS-compliant ETF, which is automatically classified as non-complex under MiFID II Article 25(4)(a)(iv), unless it is a structured UCITS or fails the Article 57 criteria[1]. The fund primarily invests in investment-grade, U.S. Dollar-denominated, short-term fixed, variable, and floating rate debt securities, with no indication of synthetic replication, significant derivative use, leverage, swaps, or inverse strategies. Derivatives, if used, are limited to efficient portfolio management (EPM) and are not central to the investment objective. The fund does not track a benchmark but is actively managed, which does not in itself introduce complexity under MiFID II. There is no evidence of embedded derivatives, contingent convertible bonds, complex indices, or other features that would make the structure or risks difficult for a retail investor with basic knowledge to understand. The fundu2019s risk profile is low (category 2), reflecting market and credit risk typical of short-duration bond funds, not structural complexity. All relevant information is publicly available in the Key Investor Document. Therefore, the fund meets all criteria for non-complex classification under MiFID II[1]."
}