{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management and currency hedging, but not central to strategy; no embedded derivatives, structured products, or complex indices; no significant leverage or contingent convertible bonds.",
    "classification": "non-complex",
    "supporting_data": "The UBS MSCI Switzerland 20/35 UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. It may use derivatives for efficient portfolio management (EPM) and to hedge currency risk, but derivatives are not central to its investment objectiveu2014the fund primarily holds the underlying securities. The use of OTC derivatives introduces counterparty risk, but this is mitigated by a collateral policy. There is no evidence of embedded derivatives, structured products, complex indices, or significant leverage. The fund may engage in securities lending, but this is a secondary feature and managed within UCITS rules. The risk profile reflects market volatility (equity risk), not structural complexity. The structure, risks, and investment objective are straightforward and can be understood by retail investors with basic knowledge. The fund does not exhibit features that would override the UCITS presumption of non-complexity under MiFID II Article 25(4) and Delegated Regulation Article 57[1]. ESMA guidance confirms that UCITS are generally non-complex, and only structured UCITS (those with algorithm-based payoffs or similar complex features) are excluded from this presumptionu2014this ETF does not meet that definition[2]. Therefore, despite limited derivative use for EPM and hedging, the ETF remains non-complex."
}