{
    "type": "ETP",
    "ucits": false,
    "replication_method": "physical",
    "leverage": true,
    "derivatives": false,
    "swaps": false,
    "inverse": true,
    "complex_factors": [
        "Leverage",
        "Inverse exposure",
        "Daily compounding and rebalancing",
        "High risk rating (7/7)",
        "Sophisticated investor target",
        "Potential for significant tracking error over multiple days"
    ],
    "classification": "complex",
    "supporting_data": "The product is a Collateralised Exchange Traded Security (ETP) that seeks to provide -3x the daily return of Taiwan Semiconductor Manufacturing Company ADR, tracking the iSTOXX Inverse Leveraged -3x TSM Index. It uses physical replication by holding short positions in the underlying ADR stock and cash balances, with no indication of synthetic replication or swap usage. The product is highly leveraged (-3x) and inverse, with daily rebalancing and compounding effects that cause returns over periods longer than one day to deviate significantly from the simple leveraged multiple of the underlying asset. The risk indicator is at the highest level (7/7), indicating very high risk. The product is intended for sophisticated investors able to monitor positions daily and understand leverage and compounding risks. There is no capital protection, and investors can lose their entire investment. The product is not UCITS compliant. No derivative instruments are used inherently in the strategy, but leverage and inverse exposure are key complexity drivers. The product\u2019s complexity arises primarily from its leverage, inverse exposure, daily compounding, and the sophisticated understanding required to manage the risks, rather than from derivatives or swap usage. The PRIIPs KID and factsheet confirm physical replication and no swap usage. The product\u2019s complexity is further underscored by the explicit warnings about the compounding effect, the recommended very short holding period (1 day), and the high risk rating. These factors align with MiFID II criteria for complex financial instruments."
}