{
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI USA UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, rules-based equity index (MSCI USA). It uses derivatives only for efficient portfolio management (EPM), not as a core part of its investment strategy. The fund may engage in securities lending, but this is a secondary activity, well within UCITS limits, and does not dominate the risk profile. There is no significant leverage, no embedded derivatives, no swaps, and no inverse or complex features. The structure, risks, and objective are straightforward and easily understood by retail investors with basic knowledge. All these factors align with the MiFID II presumption that UCITS ETFs are non-complex, provided they do not employ complex strategies or hold complex underlying assets[1]. The absence of any complex factorsu2014such as synthetic replication, significant derivative exposure, leverage beyond UCITS limits, or opaque indicesu2014confirms the non-complex classification. The fundu2019s daily liquidity, transparent pricing, and comprehensive public disclosure further support this assessment."
}