{
    "type": "ETP",
    "leverage": true,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": false,
    "complex_factors": [
        "Leverage",
        "Compounding Effect",
        "High Risk Profile"
    ],
    "classification": "complex",
    "supporting_data": "The Leverage Shares 2x Long Berkshire Hathaway (BRK-B) ETP is classified as complex primarily due to its leveraged structure (2x daily exposure) and the compounding effect, which can result in returns that deviate significantly from the underlying asset's performance over longer holding periods. The product is explicitly designed for sophisticated investors who understand the risks of leverage and daily rebalancing. The high risk indicator (6 out of 7) and the warning that the product is 'not simple and may be difficult to understand' further support this classification. While the ETP uses physical replication and does not explicitly mention derivatives or swaps, the leverage and the associated risks make it inherently complex under MiFID II rules.",
    "confidence": 90,
    "counter_argument": "The ETP uses physical replication and does not explicitly rely on derivatives or swaps, which might suggest a non-complex classification. However, the leverage and the compounding effect introduce significant complexity, making it unsuitable for retail investors without specialized knowledge. The high risk profile and the explicit warnings in the KIID override any arguments for a non-complex classification.",
    "risk_level": "high",
    "comprehension_warning": true,
    "regulatory_notes": "The product is regulated by the Central Bank of Ireland and the Financial Conduct Authority, but it is explicitly marketed to sophisticated investors, indicating its complex nature."
}