{
    "ucits": false,
    "type": "ETP",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Not a UCITS, collateralised structure, exposure to diversified portfolio of ETFs/ETCs, no capital protection, medium-low risk, but not automatically non-complex under MiFID II",
    "classification": "complex",
    "supporting_data": "The Cordillera Core Balanced Strategy ETP is not a UCITS, but a collateralised exchange-traded security. Its return depends on the performance of the Solactive CWM Core Balanced Strategy Index, which tracks a diversified portfolio of ETFs/ETCs. The product does not offer capital protection and is intended for retail investors with specific knowledge or experience. While the risk indicator is medium-low (3/7), the product is not automatically non-complex under MiFID II because it is not a UCITS and does not meet the criteria for automatic non-complex classification (Article 25(4)(a)(iv) of MiFID II). Instead, it must be assessed against the Article 57 criteria for non-complex instruments. The productu2019s structureu2014collateralised, with exposure to a diversified portfolio and no capital protectionu2014means it does not automatically qualify as non-complex. The KID explicitly states, 'You are about to purchase a product that is not simple and may be difficult to understand,' which is consistent with a complex classification. There is no evidence of embedded derivatives, swaps, leverage, or inverse features in the product description. The replication method is physical, as the ETP holds collateral assets. However, the lack of UCITS status and the productu2019s structure mean it is not eligible for the automatic non-complex presumption and is therefore classified as complex under MiFID II."
}