{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives (futures, options, swaps), potential counterparty risk, exposure to non-investment grade and emerging market securities, currency risk, liquidity risk, interest rate risk, mortgage/asset-backed securities risk, credit/default risk",
    "classification": "complex",
    "supporting_data": "This UCITS ETF is actively managed and explicitly states it may invest in derivative instruments (futures, options, swaps) rather than directly in underlying securities, with returns linked to movements in underlying assets. The use of derivatives is not limited to efficient portfolio management but is integral to the investment strategy, introducing risks such as counterparty risk and potential for more volatile exposure. The fund may also invest up to 10% in non-investment grade securities and in emerging markets, adding credit and liquidity risks. The fundu2019s documentation highlights multiple complex risks (counterparty, emerging markets, liquidity, interest rate, mortgage/asset-backed securities, credit/default, currency), which are not typical of plain-vanilla, physically replicated ETFs. While UCITS ETFs are generally presumed non-complex, the active use of derivatives central to the strategy, combined with exposure to complex fixed income instruments and explicit disclosure of multiple non-standard risks, means this ETF does not meet the criteria for a non-complex instrument under MiFID II Article 57. The structure, risks, and strategies are not easily understood by a retail investor with only basic knowledge, and the productu2019s features introduce opacity and risks beyond those of a standard index-tracking UCITS ETF. Therefore, this ETF is classified as complex."
}