{
    "ucits": true,
    "type": "ETP",
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": true,
    "replication_method": "synthetic",
    "complex_factors": "Leverage, Inverse exposure, Synthetic replication, Daily rebalancing, Compounding effect, Derivative use",
    "classification": "complex",
    "supporting_data": "The product is a Leverage Shares -3x Short Alphabet (GOOG) ETP Securities, which is a collateralised exchange traded security (ETP), not a UCITS ETF. It aims to provide -3 times the daily performance of Alphabet Inc. equity, using a synthetic replication method via the iSTOXX3x Inverse Leveraged GOOG Index. The product uses leverage (3x inverse exposure) and derivatives to achieve its objective, with daily rebalancing causing a compounding effect that can significantly alter returns over holding periods longer than one day. The product is non-interest bearing, not capital protected, and carries high risk (risk class 7/7). It involves counterparty risk and collateral risk due to derivative use. The recommended holding period is only 1 day, reflecting the complexity and risk of the product. These featuresu2014leverage, inverse exposure, synthetic replication, derivative use, and complex payoff structureu2014make it difficult for a retail investor with basic knowledge to understand the risks and payoff, thus classifying it as complex under MiFID II criteria. Although UCITS ETFs are generally presumed non-complex, this product is not a UCITS ETF and exhibits multiple complexity factors. According to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such leveraged, inverse, synthetic products with embedded derivatives and complex risk profiles are complex financial instruments requiring appropriateness assessments for retail investors."
}