{
    "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 Index; securities lending possible but secondary",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions - MSCI EMU UCITS ETF is a UCITS-compliant ETF that tracks the MSCI EMU Index primarily through physical replication, investing directly in the underlying securities or via derivatives only when direct replication is impracticable or to gain efficiencies. The derivatives used are mainly for efficient portfolio management (EPM), with counterparty risk mitigated by a collateral policy. The ETF may engage in securities lending, which introduces some counterparty risk but is managed within UCITS rules and does not dominate the risk profile. There is no indication of embedded derivatives, leverage beyond UCITS limits, or complex structured products such as CLOs. The ETF's structure and risks (market volatility, tracking error) are straightforward and transparent to retail investors with basic knowledge. The risk category is high due to market volatility but this does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation, UCITS ETFs that use physical replication and derivatives only for EPM with minimal risk impact are generally classified as non-complex. The ETF does not embed derivatives integral to its investment objective (e.g., synthetic replication), nor does it have complex features that would trigger a complex classification. Therefore, it is classified as non-complex under MiFID II rules."
}