{
    "ucits": false,
    "type": "ETP",
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": true,
    "replication_method": "synthetic",
    "complex_factors": "Leverage, Swaps, Synthetic Replication, Daily Reset, Compounding Effect, High Risk Profile, No Capital Protection, Complex Index, Futures Roll Costs, Contango/Backwardation Effects",
    "classification": "complex",
    "supporting_data": "The product is a leveraged (3x daily inverse) ETP, not a UCITS, and uses synthetic replication via swaps and futures to achieve its objective. It targets a complex index (NASDAQ-100 3x Inverse Total Return Index) and involves daily resetting of leverage, which introduces a compounding effect that is difficult for retail investors to understand. The use of derivatives (swaps, futures) is central to the strategy, introducing counterparty risk, collateral risk, and roll costs. The product is explicitly intended for informed investors, carries the highest risk indicator (7/7), and does not offer capital protection. The structure, risks, and payoff are not straightforward and require advanced knowledge to comprehend, especially due to the effects of daily leverage reset, futures rolling, and potential contango/backwardation. These features make the product complex under MiFID II Article 57 criteria, as it involves actual or potential liability beyond the cost of acquisition, uses derivatives integral to the strategy, and has a structure that is not easily understood by the average retail investor."
}