SEC Comment Letter for UBS AG (AMUB, BDCX, BDCZ, CEFD, HDLB, IFED, IWDL, IWFL, IWML, MLPB, MLPR, MTUL, MVRL, PFFL, QULL, SCDL) (CIK 0001114446) (AMUB) — May 20, 2011
UBS AG (AMUB, BDCX, BDCZ, CEFD, HDLB, IFED, IWDL, IWFL, IWML, MLPB, MLPR, MTUL, MVRL, PFFL, QULL, SCDL) (CIK 0001114446)
Date: May 20, 2011 · CIK: 0001114446 · Accession: 0000000000-11-031823
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 18, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE May 20 , 2011 By U.S. Mail and Facsimile to: (203) 719- 0680 John Cryan Group Chief Financial Officer UBS AG Bahnhofstrasse 45 CH-8001 Zurich, Switzerland
Re: UBS AG Form 20- F for the Fis cal Year Ended December 31, 2009 Form 6 -K furnished May 4, 2010 Form 6 -K furnished July 27, 2010 File No. 001 -15060
Dear Mr. Cryan :
We have reviewed your response to our letter dated January 18, 2011 and have the following additional comments. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your f acts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Form 20- F for the Fiscal Year Ended December 31, 2009 General 1. Please refer to comment 4 in our letter dated January 18, 2011. Please provide us the information regarding the amount of assets and revenues relating to contacts in Iran, Syria, Sudan and Cuba for 2008 and 2009, and for the period since the close of fiscal 2010, requeste d in the comment. 2. Please discuss for us the applicability of the sanctions recently enacted by the U.S. government under the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010 (and the corresponding Iranian Financial Sanctions
John Cryan UBS AG May 20 , 2011 Page 2
Regulati ons) with respect to maintaining accounts for Iranian parties. If these sanctions are applicable, please discuss how they are expected to impact your business. In this respect, please discuss the extent to which you are party to contracts with the U.S. government.
Exhibits, page 21 Exhibit 4.1 3. We note your response to comment 6 in our letter dated January 18, 2011. Please confirm that if and when Exhibit E is unsealed, you will refile the Deferred Prosecution Agreement in its entirety.
Closing Commen ts You may contact Angela Connell at (202) 551- 3426 or Hugh West , Accounting Branch Chief, at (202) 551- 3872 if you have questions regarding comments on the financial statements and related matters. Please contact Justin Dobbie at (202 ) 551- 3469 or me at (202) 551 -3366 with any other questions.
Sincerely,
Michael Seaman
Special Counsel
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
May 20 , 2011
By U.S. Mail and Facsimile to: (203) 719- 0680
John Cryan
Group Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland
Re: UBS AG
Form 20- F for the Fis cal Year Ended December 31, 2009
Form 6 -K furnished May 4, 2010
Form 6 -K furnished July 27, 2010
File No. 001 -15060
Dear Mr. Cryan :
We have reviewed your response to our letter dated January 18, 2011 and have
the following additional comments. Please respond to this letter within ten business days
by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your f acts and
circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we
may have additional comments.
Form 20- F for the Fiscal Year Ended December 31, 2009
General
1. Please refer to comment 4 in our letter dated January 18, 2011. Please provide us
the information regarding the amount of assets and revenues relating to contacts in Iran, Syria, Sudan and Cuba for 2008 and 2009, and for the period since the close of fiscal 2010, requeste d in the comment.
2. Please discuss for us the applicability of the sanctions recently enacted by the U.S. government under the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010 (and the corresponding Iranian Financial Sanctions
John Cryan
UBS AG
May 20 , 2011
Page 2
Regulati ons) with respect to maintaining accounts for Iranian parties. If these
sanctions are applicable, please discuss how they are expected to impact your
business. In this respect, please discuss the extent to which you are party to contracts with the U.S. government.
Exhibits, page 21
Exhibit 4.1
3. We note your response to comment 6 in our letter dated January 18, 2011. Please
confirm that if and when Exhibit E is unsealed, you will refile the Deferred Prosecution Agreement in its entirety.
Closing Commen ts
You may contact Angela Connell at (202) 551- 3426 or Hugh West , Accounting
Branch Chief, at (202) 551- 3872 if you have questions regarding comments on the
financial statements and related matters. Please contact Justin Dobbie at (202 ) 551- 3469
or me at (202) 551 -3366 with any other questions.
Sincerely,
Michael Seaman
Special Counsel