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CORRESP

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    UBS AG

Postfach

8098 Zürich

Tel. +41-44-234 11 11

    Corporate Center

Group CFO Management

    Tom Naratil

    Via EDGAR

Ms. Stephanie L. Hunsaker

Senior Assistant Chief Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington DC 20549-1090

    Tel. +41 44 234 24 07

Fax +41 44 234 21 00

tom.naratil@ubs.com

www.ubs.com

16 September 2011

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

Dear Ms. Hunsaker:

We respectfully submit the responses set forth below to the comment letter dated August 22, 2011
(the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) relating to (a) the annual report on Form 20-F for the fiscal year ended December 31,
2010 (the “2010 Form 20-F”), and (b) the second quarter 2011 report on Form 6-K (the “Q2 2011 Form
6-K”) of UBS AG (“UBS” or the “Company”). For your convenience, we have set out the text of each
comment contained in the Comment Letter, followed by our response.

Comment 1

Form 20-F for Fiscal Year Ended December 31, 2010

Risk management and control, page 116

Impairment and default — distressed claims, page 128

We note that in your retail and corporate banking business in Switzerland you typically review
individual positions for impairment only after they have been in arrears for a certain time. In
future filings please specify the length of time (e.g., 90 days, 180 days, etc.) for each loan
category that you would wait before evaluating the loan individually for impairment.

Loans in arrears for 90 days are evaluated individually for impairment. However, an impairment
analysis would be carried out irrespective of whether the loan was in arrears if other objective
evidence indicates that a loan may be impaired. We will clarify our disclosure in this regard for
future filings.

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

16 September 2011

Page 2 of 11

Comment 2

Regulation and supervision in the US, page 216

We note your brief discussion of the Dodd-Frank Act and the so-called Volcker rule which may limit
the ability of deposit-taking banks to engage in proprietary trading activities and invest in hedge
funds and private equity. To the extent reasonably known, please clarify the extent to which your
proprietary trading activities will be subject to the Volcker rule under the US Dodd-Frank Act. In
this regard, please provide your analysis of the applicability of the Volcker rule to your
operations conducted both within and outside the US.

Although the relevant regulators have not yet proposed implementing regulations for Section 619 of
the Dodd-Frank Act (the “Volcker rule”), UBS expects that “bright line” proprietary trading
activities conducted by it in the United States will be prohibited under the Volcker rule. UBS is
currently in the process of identifying those bright-line proprietary trading activities, and
management is evaluating options for the redeployment, closure or disposition of businesses that
are likely to be considered bright-line proprietary trading in the US. The Volcker rule excludes
from its scope, activities of foreign financial institutions conducted solely outside the US. Based
on existing interpretations of US banking law, we believe that bright-line proprietary trading
activities booked and managed outside the US will likely not be prohibited by the Volcker rule. The
Volcker rule also permits principal trading if, among other things, the trading constitutes market
making, trading “on behalf of customers”, or hedging. Management is evaluating the quantitative
metrics suggested by the Financial Stability Oversight Council from its study released in January
2011. In conclusion, UBS cannot comment on the impact of the Volcker rule on UBS’s operations until
the regulations ultimately adopted by various agencies are finalized and management has completed
its evaluation.

Comment 3

Financial Statements and Notes

Note 1 — Summary of significant accounting policies, page 273

3) Subsidiaries, page 273

We note your accounting policies related to SPEs, including SPEs that are used to allow clients to
hold investments, those that are used for securitization when UBS has assets it sells to an SPE,
and SPEs used for credit protection. We also note from review of your Basel II Pillar 3 disclosures
on page 185 that you have done some resecuritization transactions, but it is unclear how these
transactions are accounted for in your financial statements. Please tell us the following:

    •

    whether you consolidate any of your re-securitization vehicles, and provide us with
your accounting analysis to support the non-consolidation of any of these vehicles.

UBS has not originated any SPEs used for re-securitization in any of the periods presented and the
vast majority of the positions classified as re-securitization positions in the Basel II Pillar 3
disclosures on page 185 were acquired in the secondary market and were not originated by UBS.

We do not consolidate any of the re-securitization SPEs related to the re-securitization positions
reported in the Basel II Pillar 3 disclosures on page 185. Those re-securitization amounts
represent positions in collateralized loan obligations and collateralized debt obligations and were
classified as re-securitization exposures pursuant to the interpretation of the Basel II Pillar 3
disclosure rules. As described in Note 1 on page 274, “UBS does not consolidate SPEs for
securitization if it has no control over the assets and if it no longer retains any significant
exposure (for gain or loss) to the income or investment returns on the assets sold to the SPE or
the proceeds of their liquidation.” UBS neither exercises control over, nor has the majority of
risks and rewards in these re-securitization SPEs; consequently, UBS does not consolidate the
re-securitization SPEs.

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

16 September 2011

Page 3 of 11

Comment 3, continued

    •

    quantify the total assets of your re-securitization vehicles and amount of
securities that were re-securitized in the periods presented

UBS has not originated any re-securitization SPEs in any of the periods presented; consequently, no
additional quantitative information has been provided. Approximately CHF 1.7 billion of the
positions reported as re-securitization positions in the Basel II Pillar 3 disclosure on page 185
relate to re-securitization SPEs that were originated by UBS in periods prior to 2008. The
remaining positions (approximately CHF 5 billion) were acquired in the secondary market.

Comment 3, continued

    •

    To the extent that certain of your resecuritization transactions are consolidated
and certain are not, please separately quantify the amounts for each type.

As noted, we did not originate any re-securitization SPEs in any of the periods presented and we do
not consolidate any of the re-securitization SPEs.

Comment 3, continued

    •

    Tell us whether your clients request the re-securitization and, if so, the types of
parties that request your assistance in performing the re-securitization, and discuss
their role in the design of the vehicle and the structure of the securities to be
issued.

As noted, we did not originate any re-securitization SPEs in any of the periods presented.

Comment 3, continued

    •

    whether there are situations in which you are doing re-securitizations for your own
liquidity or capital purposes, and tell us the other parties involved that have
discretion over the design of the vehicle.

As noted, we did not originate any re-securitization SPEs in any of the periods presented.

Comment 4

24) Equity participation and other compensation plans, page 284

We note your disclosure that plans containing voluntary termination and non-compete provisions and
no vesting conditions are considered vested at the grant date because no future service is
required. In these cases, compensation expense is fully recognized on the grant date or is
recognized in a period prior to the grant date if the bank can substantiate that the award is
attributable to past service and the amount can be reliably estimated. We also note your disclosure
on page 352 that compensation for all SESAP and SESOP awards is recognized during the performance
year, which is generally the period prior to the grant date, as well as your disclosure that
compensation expense for your cash balance plan is recognized in the performance year, which is
generally the period prior to the grant date. Please tell us in more detail how you believe you can
reliably estimate the expense prior to the grant date and tell us the typical time period involved
between expense measurement and the grant date.

The performance year bonus accrual covers all cash bonuses, as well as any share-based compensation
awards where, from an accounting perspective, no future service is required from the employee
(“non-service-based plans”). Non-service-based plans include the cash balance plan (“CBP”) and any
equity ownership plan (“EOP”) awards where the employee is expected to meet the retirement
eligibility requirements at the date of grant. The bonus accrual represents a determined monetary
amount, which is
converted into cash, deferred cash and share or other instruments, based on their fair value at the
grant date. Amounts to be awarded under each of the plans are estimated by reference to the
compensation funding framework agreed upon by the Human Resources and Compensation Committee
(“HRCC”) (a sub-committee of the Board of Directors) and approved by the full Board of Directors
(please refer to pages 237-239 of the Annual Report for more details).

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

16 September 2011

Page 4 of 11

Employees who receive annual performance-related compensation above a certain threshold receive a
portion of it in the form of an EOP award. Compensation expense is recognized in the performance
year for those employees that no longer have to provide future service as a result of being
retirement eligible at the date of grant. The determination of the retirement eligible population
for the accrual is based upon historical data.

The CBP is awarded as part of Group Executive Board members’ annual bonus. In determining the
annual cash bonus we do not distinguish between amounts paid immediately and amounts deferred under
the CBP. Once the annual cash bonus is established we determine the amounts subject to the CBP by
applying a pre-defined formula to the notional bonus awarded.

For SESAP and SESOP annual cycle awards, our historic estimation process involved a forecast of the
estimated quantity of options and stock appreciation rights to be granted under these plans. UBS
recognized compensation expense based on the estimated quantity of options to be granted multiplied
by the option price in effect at the reporting date. These amounts recognized were revised each
period until final grant based on an updated option price and forecasted grant quantity. Please
note that SESAP and SESOP annual cycle awards are no longer granted; the last of these awards were
granted in February 2008 for the 2007 performance year.

Based on the compensation funding framework that is in place, we believe that we have reliable
information sufficient to record an accrual for these awards in the performance year. The period of
time between the final measurement date for annual financial reporting and finalization of the
grant amount is approximately one month.

Comment 5

(b) Changes in accounting policies, comparability and other adjustments, page 288

Equity and Other comprehensive income, page 289

We note your disclosure on page 41 where you state that you recognized an out-of-period credit of
CHF 592 million resulting from the correction of prior period misstatements, and that your total
comprehensive income attributable to UBS shareholders for the year ended December 31, 2010 was CHF
5.9 billion (and a CHF 3.3 billion loss for the year ended December 31, 2009). We further note your
disclosure on page 289 that the foreign currency balance was adjusted by CHF 592 million and that
it increased total other comprehensive income by CHF 592 million and total comprehensive income by
CHF 429 million because a loss of CHF 163 million was transferred to the income statement. However,
we were unable to locate a discussion describing the nature of the misstatements or an
understanding of how the misstatements occurred or were identified. Please respond to the
following:

    •

    Tell us the nature of the misstatements identified and separately quantify the
amount of each misstatement by type.

    •

    Tell us how the misstatements were identified. As part of your response, please tell
us whether changes were made to your internal controls over financial reporting to
prevent these types of misstatements in the future.

As a result of a number of targeted control reviews designed to improve accounting controls over
certain balance sheet accounts and, in particular, the accounting for foreign currency translation
(“FCT”), UBS identified certain errors which are explained below.

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

16 September 2011

Page 5 of 11

Review of parent bank balance sheet verification processes

This review focused on improving the processes to verify certain balance sheet accounts in the UBS
AG parent bank. As a result of the review, we identified that certain other liabilities and certain
FCT balances within other comprehensive income relating primarily to foreign branches were
misstated. The correcting entries for these misstatements were (i) a debit to other income of CHF
227 million and a credit to the FCT account within other comprehensive income of CHF 227 million
and (ii) a debit to other liabilities of CHF 227 million and a credit to other income of CHF 227
million.

Review of FCT related to acquisitions and dispositions

A separate but related review focused on the accounting for FCT procedures in general and the
treatment of FCT balances upon partial disposals in particular. This review made a number of
control recommendations which have been implemented, but confirmed that the overall processing
within the ledgers for FCT balances was sound. However, it identified that FCT was not transferred
from the FCT account within other comprehensive income to the income statement in respect of
partial disposals of subsidiaries. The correcting entry for this misstatement was a debit to other
income of CHF 163 million and a credit to the FCT account within other comprehensive income of CHF
163 million.

A subsequent detailed review of FCT accounting also identified an error that had been made on the
acquisition of non-controlling interests in a foreign consolidated subsidiary. Incorrect accounting
entries had been made in connection with the booking of contingent purchase price consideration,
resulting in overstated share premium amounts and understated FCT amounts. The correcting entry
resulted in a debit to share premium of CHF 78 million and a credit to FCT within other
comprehensive income of CHF 78 million.

Review of tax accounts in equity

As part of the 2010 year-end review of the equity accounts that are used for Swiss tax purposes, a
posting error was identified relating to deferred tax assets for Swiss tax losses. Further checks
demonstrated that this was an isolated error and processes were changed; hence, we believe that
such errors would be prevented from recurring. The cor