{
    "type": "ETP",
    "ucits": false,
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Leverage",
        "Synthetic replication",
        "Use of derivatives (swaps)",
        "Daily rebalancing and compounding effects",
        "High risk profile (risk class 7/7)",
        "Complex payoff structure (2x daily leverage)",
        "Potential counterparty and collateral risk",
        "Lack of capital protection",
        "Short recommended holding period",
        "Compounding effect and volatility impact"
    ],
    "classification": "complex",
    "supporting_data": "The product is a leveraged ETP Securities product providing 2x daily exposure to Tesla equity, using a synthetic replication method via swaps held in a margin account. It explicitly uses derivatives integral to its investment objective, introducing counterparty and collateral risks. The product has a high risk rating (7/7), no capital protection, and a complex payoff profile due to daily leverage and compounding effects, which retail investors with basic knowledge would find difficult to understand. The recommended holding period is only 1 day, reflecting the complexity and risk of holding longer. The product is not UCITS compliant but is regulated by the Central Bank of Ireland and FCA. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, such use of derivatives for synthetic replication and leverage, combined with complex payoff and risk features, classifies the product as complex. ESMA guidance confirms that synthetic ETFs and leveraged products are complex and require appropriateness assessments. Therefore, this ETP must be classified as complex under MiFID II."
}