{
    "success": true,
    "data": {
        "leverage": true,
        "derivates": true,
        "swaps": true,
        "inverse": true,
        "replication_method": "synthethic",
        "ucits": false,
        "type": "ETP",
        "complex_factors": "Short exposure to volatility via shorting volatility assets using derivatives. Strategy aims to capture contango of futures volatility curve which implies using roll yields. The ETP uses a long Tech exposure and a short volatility strategy, using derivatives, to achieve its objective, including those using futures, and replicating volatility.",
        "classification": "complex",
        "supporting_data": "The LS Short Volatility Long Tech ETP (Exchange Traded Product) is classified as a complex asset. This determination is primarily based on several factors: The product aims to replicate a strategy involving a short exposure to volatility and a long tech-biased exposure. It uses Short volatility assets using derivatives, specifically the iPathu00ae Series B S&P 500u00ae VIX Short-Term Futuresu2122 ETNs and ProShares VIX Short-Term Futures ETF . The underlying strategy's design to capture the contango of the futures volatility curve indicates the use of futures contracts, which are derivatives, and introduces potential roll costs and contango effects. The use of derivatives to achieve the investment objective is a key indicator of complexity, as highlighted in the MiFID II assessment rules (Rule 2). Furthermore, the product has an element of significant leverage and involves shorting of a complex index. The intended retail investors are expected to have some knowledge of financial markets, suggesting the product is at least somewhat complex. The KID document includes a comprehension alert, which is mandatory for complex ETFs (MiFID II, Section 7). Therefore, based on the significant use of derivatives, the reliance on futures contracts to replicate volatility and a long tech exposure strategy, the lack of ease of understanding of the underlying asset, the use of leverage, and the comprehension alert, this ETP meets the criteria for classification as a complex product under MiFID II. The asset is also not UCITS compliant, and the strategy uses derivatives for replicating the volatility index.",
        "comprehension_alert": true,
        "supporting_esma_references": [
            "ESMA's supervisory briefing on appropriateness and execution-only",
            "ESMA Guidelines on complex debt instruments and structured deposits",
            "MiFID II Article 25(3) and (4) and Article 57",
            "The ESMA guidelines on complex debt instruments and structured deposits dated 4 February 2016 and Q&A1 in relation to appropriateness/complex financial instruments."
        ]
    }
}