{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI USA Consumer Discretionary UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, well-diversified equity index (MSCI USA Consumer Discretionary 20/35 Custom Index). The fund may use derivatives only for efficient portfolio management (EPM), not as a core part of its investment strategy, and does not engage in synthetic replication, securities lending, or leverage beyond UCITS limits. The structure, risks (market volatility, sector concentration), and investment objective are straightforward and disclosed in the KID. There are no embedded derivatives, complex indices, or contingent convertible bonds. The ETF meets all MiFID II criteria for non-complex UCITS ETFs: it is UCITS-regulated, uses physical replication, has no material derivative exposure, and its risks are easily understood by retail investors with basic knowledge[1]. No features trigger complexity under Article 57 of Delegated Regulation (EU) 2017/565."
}