{
    "ucits": true,
    "type": "ETP",
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Leverage",
        "Synthetic replication via swaps",
        "Embedded derivatives",
        "Counterparty risk",
        "Collateral risk",
        "Daily leverage reset and compounding effects",
        "Opaque payoff structure",
        "High risk rating (7/7)"
    ],
    "classification": "complex",
    "supporting_data": "The GraniteShares 3x Long UBER Daily ETP is a collateralised exchange traded product that seeks to replicate 3 times the daily performance of Uber Technologies Inc via a swap with Natixis. It uses synthetic replication through total return swaps, which introduces counterparty and collateral risks. The product employs significant leverage (3x daily), with a daily reset of leverage causing compounding effects that make returns over periods longer than one day deviate from simple multiples of the underlying asset's returns. The structure is complex and not straightforward for retail investors to understand, especially given the embedded derivatives and the risks associated with the swap counterparty and collateral management. The product is explicitly described as 'not simple and may be difficult to understand' and carries the highest risk class (7/7). According to MiFID II Article 25(4)(a)(vi) and Article 57 of the Delegated Regulation, such use of derivatives integral to the investment objective, leverage beyond UCITS limits, and synthetic replication classify the product as complex. The product is not a UCITS ETF but an ETP, which further supports complexity classification. Therefore, it requires an appropriateness assessment before sale to retail clients under MiFID II rules."
}