{
    "type": "ETP",
    "ucits": false,
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Leverage, Derivative exposure, Complex underlying reference asset",
    "classification": "complex",
    "supporting_data": "The product is an Exchange Traded Product (ETP) issued by Leverage Shares plc, not a UCITS fund, thus 'ucits' is false. It provides 1:1 leveraged exposure to the ARK NextGen Internet ETF, indicating the use of leverage, which is confirmed by the issuer's name and product description. The product invests subscription proceeds directly into the Reference Asset (the ARK NextGen Internet ETF) and collateral assets, held in a margin account, implying derivative or leveraged exposure. The KID states the product is collateralised and non-interest bearing, with no capital protection and a high risk indicator (6/7), reflecting significant market and structural risks. The product is described as complex and includes a comprehension alert stating 'You are about to purchase a product that is not simple and may be difficult to understand.' This confirms the complex classification. The replication method is physical in the sense that the ETP invests directly in the Reference Asset (an ETF), not synthetic replication via swaps. However, the leverage and collateralised structure introduce complexity. Derivatives are used as part of the leveraged exposure, but since the product is collateralised and the underlying is an ETF, swaps are not explicitly mentioned, so 'swaps' is false. The product does not use inverse strategies. According to MiFID II rules and ESMA guidance, leverage beyond UCITS limits and derivative use integral to the strategy make the product complex. The product's structure, leverage, and derivative exposure make it difficult for retail investors with basic knowledge to understand the risks, fulfilling the criteria for complexity under MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57. Therefore, the product is classified as complex."
}