{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF, which under MiFID II is generally presumed non-complex due to strict regulatory requirements ensuring diversification, liquidity, and transparency. The ETF described tracks the MSCI USA Prime Value Advanced Target Select 100% Hedged to EUR Index through direct investments in the index's component securities, indicating physical replication. The fund uses derivatives only for currency hedging and efficient portfolio management, which is limited and does not significantly impact the risk-return profile. There is no indication of embedded derivatives, synthetic replication, leverage beyond UCITS limits, or complex structured products such as CLOs. The ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. The index tracked is transparent and well-documented. Securities lending is not used. The risk profile is high due to market volatility but this does not imply complexity. Therefore, the ETF meets the criteria for non-complex classification under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, and no appropriateness assessment or comprehension alert is required."
}