{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives (including swaps) used for investment purposes, not just efficient portfolio management; potential counterparty risk; concentration risk; high risk category (7/7); possible use of synthetic instruments in limited circumstances",
    "supporting_data": "The Global X FinTech UCITS ETF is a UCITS-compliant, physically replicated ETF that primarily invests in equity securities to track its index. However, the fund explicitly states it may use financial derivative instruments (FDIs), including total return unfunded OTC swaps and exchange-traded equity futures, for investment purposesu2014not solely for efficient portfolio management. This introduces counterparty risk and potential complexity, as the use of derivatives is integral to the strategy in certain market conditions. The fund is in the highest risk category (7/7) due to the volatility of its underlying investments, and it highlights concentration risk, as its portfolio is highly concentrated in fintech companies. While the fundu2019s base strategy is physical replication, the possibility of using swaps and other derivatives for investment (not just hedging) means the productu2019s risk profile and structure may not be straightforward for the average retail investor to understand. The fundu2019s documentation is transparent about these risks, but the presence of derivatives as a core part of the strategy (not just ancillary) is a key factor in complexity under MiFID II. The fund does not use significant leverage beyond UCITS limits, does not offer capital protection, and is not inverse. The index tracked is transparent, but the fundu2019s ability to use derivatives for investment (not just hedging) and the associated risks (counterparty, collateral) are material to the complexity assessment.",
    "classification": "complex"
}