{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The UBS FTSE 100 UCITS ETF (ISIN LU0136242590) is a UCITS-compliant ETF that primarily invests directly in the component securities of the FTSE 100 Index, employing physical replication or limited use of derivatives only for efficient portfolio management (EPM) purposes such as managing inflows/outflows or hedging currency risk. The derivatives use is limited and collateralized, mitigating counterparty risk. The ETF does not employ leverage beyond UCITS limits, does not embed complex derivatives or structured products, and tracks a transparent, well-known equity index. The risk profile reflects market volatility typical of equity investments but does not indicate structural complexity. Securities lending is possible but managed within UCITS rules and does not dominate the risk profile. The ETF's structure and risks are straightforward and understandable by retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs that use physical replication and limited derivatives for EPM are presumed non-complex. The ETF does not meet any criteria for complexity such as synthetic replication, embedded derivatives, significant leverage, or opaque index exposure. Therefore, it is classified as non-complex under MiFID II and does not require an appropriateness assessment or comprehension alert in the PRIIPs KID. This aligns with ESMA and CESR guidance that UCITS ETFs with physical replication and limited derivative use for EPM are non-complex, while synthetic or structured UCITS ETFs would be complex. The ETF's risk category 5 reflects market volatility, not structural complexity. Hence, the classification is non-complex."
}