{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for risk reduction and currency hedging; securities lending; complex index weighting",
    "classification": "non-complex",
    "supporting_data": "The fund is a UCITS ETF, which under MiFID II is generally presumed non-complex. It tracks the MSCI USA Select Dynamic 50% Risk Weighted 100% hedged to EUR Index by holding essentially all shares in the index in the same proportions, indicating physical replication. The use of derivatives is limited to risk reduction, cost reduction, and currency hedging, which aligns with efficient portfolio management (EPM) and does not form an integral part of the investment objective. The derivatives use may multiply gains or losses but is described as limited and for hedging purposes, not synthetic replication or embedded derivatives. Securities lending is employed but within UCITS rules and collateral requirements, which does not automatically trigger complexity. The index tracked is transparent and equity-based, supporting non-complex classification. The risk profile is high due to market volatility (risk category 5 or 6), but this reflects market risk, not structural complexity. There is no indication of leverage beyond UCITS limits or embedded derivatives such as structured products or swaps integral to replication. Therefore, the ETF meets the criteria for non-complex instruments under MiFID II Article 25(4)(a)(iv) and Article 57, as it uses physical replication, limited derivatives for EPM, and has transparent structure and risks understandable by retail investors with basic knowledge. The presence of derivatives for hedging does not automatically make it complex, consistent with ESMA guidance and MiFID II rules. Hence, the classification is non-complex."
}