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CORRESP
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Correspondence

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    UBS AG

Postfach

CH-8098 Zürich

Tel. +41-44-234 11 11

Group Tax & Accounting Policy

Todd Tuckner

Stockerstrasse 64

Tel. +41-44-234 8280

Fax +41-44-234 7361

todd.tuckner@ubs.com

www.ubs.com

Ms. Kathryn McHale

Assistant Chief Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

March 28, 2011

UBS AG

Form 20-F for the fiscal year ended December 31, 2009

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

Dear Ms. McHale:

On October 8, 2010, we submitted our responses to your comment letter dated September 9, 2010 (the
“Comment Letter”) relating to UBS AG’s (a) annual report on Form 20-F for the year ended December
31, 2009, (b) first quarter 2010 report on Form 6-K, and (c) second quarter 2010 report on Form
6-K.

On March 15, 2011, we filed our Annual Report 2010 on Form 20-F, which included the disclosures we
committed to in our response letter. Here, we take the opportunity to provide you with the table
we shared with UBS’s Audit Committee of the Board of Directors earlier this month during the
Annual Report governance meetings. We thought this might assist you in your follow-up review.

Specifically, the enclosed table includes references to the comments made in your Comment Letter,
our disclosure commitments, the specific page / table reference of the disclosures included in our
Annual Report 2010 and additional information where applicable. Comments No. 1, 4, 9, 11 and 14 of
the Comment Letter did not include requests for enhanced disclosures and are therefore excluded
from the table. We note that there were follow-up discussions with your colleagues in connection
with comments 9 and 14.

Please contact me if you have any questions or comments.

Very truly yours,

UBS AG

Todd Tuckner

Head, Group Tax and Accounting Policy

    SEC

    UBS’s commitment
 regarding enhanced

    Page in the

    comment

    SEC comment on

    disclosures in the

    Annual Report

    No.

    Annual Report 2009

    Annual Report 2010

    2010

    Background

    2

    Risk and treasury management
Composition of credit risk —
UBS Group, page 119

    We agree to more clearly define how
our gross credit exposure was
determined.

We agree to more clearly define the
linkage between the various credit
exposure tables.

    page 123

page 126

page 127

page 129

    Page 123, table credit exposure by business division: added footnote 2, to explain that reclassified & acquired
securities are excluded from the credit exposure table, and also added footnote 4 to tie back to IB IFRS gross banking
products exposure as per page 129 table ‘Allowances and provisions for credit losses’ (page 123 table does not include
reclassified and acquired securities and also deducts internal risk adjustments).

Page 126 (table Investment Bank: banking products and OTC derivatives exposure: changed footnotes 1) and 2) to help
tie the numbers back to page 123 table (money market & nostro account explain the difference).

Page 129 (table Allowances and provisions for credit losses): table content has been simplified and clarified (the
numbers on the 2nd column ‘IFRS exposure, gross’ include reclassified assets and acquired securities) to ease
reconciliation of IFRS accounting view to risk view. ‘IFRS exposure, gross’ can be reconciled to UBS IFRS
balance-sheet once allowances for credit losses (shown on the 6th column) are deducted (applies to ‘balances with
central banks’, ‘due from banks’ and ‘loans’).

Moreover, on page 127 we enhanced our industry & geographic breakdowns to show net OTC derivatives exposures.

    3

    Composition of credit risk —
business divisions, page 120

Investment Bank, page 122

    We agree to more clearly define the
linkage between the various credit
exposure tables.

    see above

    see above

    5

    Notes to the consolidated
financial statements
Note 1(a)(11) — Allowance and
provision for credit losses,
page 267

    We agree to provide more
comprehensive disclosure on our
process for collectively measuring
impairment.

    page 278

    Section “Financial information”, Note 1a) item 11: qualitative description has been expanded, and statement that
collective impairments are not material has been included.

    6

    Note 1(a)(14) — Repurchase and
reverse repurchase
transactions, page 269

    We will eliminate“generally” to make
clear that we do not derecognise
securities in the course of a repo
transaction.

    page 279

    Section “Financial information”, Note 1a) item 14

    7

    Trading portfolio, page 294

    We will present carrying amounts for
debt instruments held for trading
and available-for-sale by product
type.

    page 305 and 307

    Section “Financial information”, Note 11 and Note 13: new tables presenting amounts by product types have been included

    8

    Note 13 — Financial Investment
available-for-sale, page 296

    We will present unrealised losses of
instruments available-for-sale
separately from unrealised gains and
provide narratives, including losses
by duration.

    page 307

    Section “Financial information”, Note 13: the table now presents the losses and gains separately. In addition, a
footnote has been included where we provide information on duration.

    10

    Note 27 — Fair value of
financial instruments, page 318

    We will provide a description on
valuation methods by product type
according to split promised under
comment 7.

    pages 337 and 338

    Section “Financial information”, Note 27c: detailed description on methods for all major product types incl. those
disclosed in Note 11/13

    12

    Note 29(b) — Measurement
categories of financial assets
and financial liabilities —
Reclassification of financial
assets, page 332

    We will include in the footnotes of
Note 9a the amount of the allowances
for credit losses related to
reclassified securities.

We will include in the footnotes of
MD&A ARS inventory table the amount
of the allowances for credit losses
related to reclassified securities.

    page 302 (table Due from
banks and loans, footnote
1); page 145 (table Student
loan ARS inventory, footnote
1)

    Section “Financial information”, Note 9a: The relevant information has been put in footnote 1 to table Note 9a Due
from banks & loans such that the amounts are agreeable to the ones disclosed in Note 29b.

Refer to MD&A, risk management, ARS inventory table: footnote has been included/expanded

    13

    Loans granted to members of the
BoD on 31 December 2008/2009,
page 392

Loans granted to members of the
GEB on 31 December 2008/2009,
page 392

    We will include the required
statement as long as Instruction 2
to Item 7.B is applicable:

“the loans in question (A) were made
in the ordinary course of business,
(B) were made on substantially the
same terms, including interest rates
and collateral, as those prevailing
at the time for comparable
transactions with other persons, and
(C) did not involve more than the
normal risk of collectability or
present other unfavorable features”.

    page 241 (text under “Loans”)

    Section “Compensation, 2010 compensation for the Group Executive Board and the Board of Directors”: the following
statement has been included: “BoD and GEB members are granted loans, fixed advances and mortgages. Such loans were
made in the ordinary course of business, on substantially the same terms as those granted to other employees,
including interest rates and collateral, and did not involve more than the normal risk of collectability or contain
other unfavorable features.”

    15

    Form 6-K furnished July 27, 2010

    If we determine that any of our
sovereign exposures are material, we
will disclose the necessary
information.

    page 131 (table Largest five
exposures to sovereign of
industrialized European
countries rated AA and
below) and 132 (table
emerging markets net
exposure by UBS internal
country rating category)

    Section “Risk and treasury management, Risk management and control”: page 131 table is new, page 132 table geographic
region granularity was expanded to show for each region the five largest exposures.