{
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": "Currency hedging via derivatives, potential use of derivatives for efficient portfolio management, counterparty risk from OTC derivatives",
    "classification": "non-complex",
    "supporting_data": "The UBS (Lux) Fund Solutions u2013 MSCI Switzerland 20/35 UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent equity index. It is currency-hedged to USD using currency forwards, which introduces derivative exposure, but this is limited to hedging currency risk and is not central to the investment strategy. The ETF may use derivatives for efficient portfolio management (EPM), such as managing inflows/outflows or reducing transaction costs, but not for speculative purposes or to achieve leveraged returns. The prospectus notes that OTC derivatives may be used, introducing counterparty risk, but this is mitigated by a collateral policy. There is no evidence of embedded derivatives, structured products, leverage beyond UCITS limits, or complex indices. The ETFu2019s structure, risks, and objectives are transparent and typical for a UCITS equity ETF. Under MiFID II, all UCITS are automatically non-complex unless they are structured UCITS or use derivatives in a way that makes the product difficult for the average retail investor to understand[1]. Here, the derivative use is ancillary (for hedging and EPM), not integral, and the product does not exhibit features that would override the UCITS presumption of non-complexity. Therefore, despite the presence of derivatives for hedging and EPM, the ETF remains non-complex under MiFID II[1]."
}