{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, possible synthetic exposure, counterparty risk, securities lending",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions u2013 MSCI EMU Small Cap UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. It is passively managed and invests predominantly in the underlying securities of the index. The fund may use derivatives for efficient portfolio management (EPM), such as managing inflows/outflows or hedging currency risk, but not as a core strategy to replicate the index. The use of OTC derivatives introduces counterparty risk, which is mitigated by the fund's collateral policy. Securities lending is permitted but is a secondary feature, managed within UCITS rules. The fund does not use significant leverage, embedded derivatives, or complex structured products. The index tracked is straightforward and well-documented. The fund's structure, risks, and objectives are transparent and can be understood by retail investors with basic knowledge. While derivative use for EPM and securities lending introduce some complexity, these features are ancillary and do not dominate the risk profile or make the product difficult to understand for the average retail investor. Therefore, the ETF remains non-complex under MiFID II, as it meets the UCITS presumption and does not exhibit features that would override this classification under Article 57 of the Delegated Regulation."
}