{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for efficient portfolio management with counterparty risk mitigated by collateral policy; physical replication of MSCI EMU Value Index; no embedded derivatives or leverage beyond UCITS limits",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI EMU Value UCITS ETF is a UCITS-compliant ETF that primarily uses physical replication of the MSCI EMU Value Index, investing directly in the underlying securities or through limited use of derivatives only when direct replication is not practicable. The derivatives used are mainly for efficient portfolio management purposes, such as managing inflows/outflows or hedging, with counterparty risk mitigated by a collateral policy. There is no indication of embedded derivatives, significant leverage, or complex structured products like CLOs. The fund's structure and risks (market volatility, tracking error) are straightforward and transparent, suitable for retail investors with basic knowledge. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such a UCITS ETF with physical replication and limited derivative use for EPM is classified as non-complex. The fund does not embed derivatives integral to its investment objective, nor does it have features that would make it complex, such as synthetic replication or structured UCITS characteristics. Therefore, it does not require an appropriateness assessment or comprehension alert under MiFID II. This aligns with regulatory guidance that all UCITS ETFs are presumed non-complex unless they have complex features, which this fund does not exhibit[1][2]."
}