{
    "ucits": true,
    "type": "ETP",
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": "Leverage, Synthetic replication, Derivative use, Daily rebalancing, Compounding effect",
    "classification": "complex",
    "supporting_data": "The product is a Leverage Shares 3x Long Oil & Gas ETP Securities, which is a collateralised exchange traded security (ETP), not a UCITS ETF. It aims to provide 3 times the daily performance of the Energy Select Sector SPDR Fund, implying significant leverage (3x). The product uses derivatives to achieve this leveraged exposure, as indicated by the daily rebalancing and compounding effects described. The use of leverage beyond UCITS limits and the synthetic replication via derivatives to achieve the investment objective introduces complexity, including counterparty risk and compounding risk, which are difficult for retail investors to understand. The product is explicitly stated as non-simple and difficult to understand, with a highest risk class (7/7) on the risk scale. It is intended for sophisticated investors with a very short holding period (1 day), further indicating complexity. The product is not capital protected and involves risks such as counterparty risk, liquidity risk, and the impact of leverage and compounding. According to MiFID II rules and ESMA guidance, such leveraged, synthetic, derivative-based products are classified as complex. The product does not qualify as a UCITS ETF and does not meet the criteria for non-complex instruments under Article 57 of the Commission Delegated Regulation. Therefore, it requires an appropriateness assessment before being sold to retail investors."
}