{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivatives (futures, options, swaps), Swaps (equity swaps, swaps on the Index), Use of derivatives for both efficient portfolio management and as an integral part of the investment strategy, Potential counterparty and collateral risk from derivative use, High risk profile (SRRI 7), Limited diversification risk, Liquidity risk, Emerging markets exposure, Exposure to smaller companies",
    "classification": "complex",
    "supporting_data": "The VanEck Crypto and Blockchain Innovators UCITS ETF is a UCITS-compliant ETF that primarily uses physical replication to track its index, investing directly in underlying equity securities. However, the fund explicitly states it may use a range of financial derivative instruments (FDIs)u2014including futures, options, swaps (equity swaps and swaps on the Index), currency forwards, and non-deliverable forwardsu2014both for efficient portfolio management and, where practical or cost-efficient, as an integral part of its investment strategy. The use of swaps, in particular, introduces counterparty and collateral risk, which are complex features for retail investors to understand. The fundu2019s risk profile is rated at the highest level (SRRI 7), reflecting very high rises and falls in value, and it highlights additional risks such as limited diversification, liquidity risk, and significant exposure to emerging markets and smaller companies. While UCITS ETFs are generally presumed non-complex under MiFID II, the central and material use of derivativesu2014especially swapsu2014and the associated risks override this presumption, making the product complex under Article 57 of the MiFID II Delegated Regulation. The fundu2019s structure, risk factors, and derivative usage mean that a retail investor with basic knowledge would likely struggle to understand the full risk profile, particularly the implications of derivative exposure. Therefore, despite being a UCITS ETF with physical replication as its primary method, the fundu2019s derivative usage and risk profile necessitate a complex classification."
}