{
    "ucits": true,
    "type": "ETF",
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Leverage, Derivatives, Daily Reset Compounding, Commodity Futures Roll Costs",
    "classification": "complex",
    "supporting_data": "The product is a WisdomTree Coffee 2x Daily Leveraged ETC, which provides 2x leveraged exposure to the Bloomberg Coffee Sub Excess Return Index. It uses futures contracts referencing the commodity index, with daily leverage reset and compounding effects that cause performance deviation over periods longer than one day. The product is a collateralised debt security (ETC), not a UCITS ETF, and is governed by Jersey law. It explicitly states high risk (7/7), no capital protection, and risks related to rolling futures contracts (roll costs, contango/backwardation effects). The use of leverage beyond UCITS limits and embedded derivatives (via futures) makes it complex under MiFID II. The productu2019s structure and risks (leverage, derivatives, counterparty and collateral risk, compounding effects) are difficult for retail investors with basic knowledge to understand. According to MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57, leveraged products with embedded derivatives and complex payoff profiles are classified as complex. The product does not qualify for the UCITS non-complex presumption and requires an appropriateness assessment before sale to retail clients."
}