{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "complex_factors": "Derivative use for efficient portfolio management and hedging, not central to investment objective",
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - Factor MSCI USA Quality Screened UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. It uses derivatives only for efficient portfolio management (EPM) and currency hedging, not as a core part of its investment strategy. The ETF does not use swaps, leverage, or inverse strategies. The structure, risks, and payoff are straightforward and easily understood by retail investors with basic knowledge. The use of derivatives is limited and well-disclosed, with counterparty risk mitigated by collateral policies. There are no embedded derivatives, complex indices, or contingent convertible bonds. The ETF meets all UCITS regulatory requirements for diversification, liquidity, and transparency, supporting its classification as non-complex under MiFID II[1]. While ESMA notes that some UCITS ETFs with complex features (e.g., synthetic replication, significant derivative exposure) may be considered complex, this ETFu2019s use of derivatives is ancillary and does not introduce material complexity[2]. Therefore, it remains non-complex."
}