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Correspondence

 UBS AG

 Postfach

 8098 Zürich

Tel. +41-44-234 11 11

 Corporate Center

 Group CFO Management

Tom Naratil

Tel. +41-44-234 24 07

 Fax +41-44-234 21 00

 tom.naratil@ubs.com

Via EDGAR

 www.ubs.com

 Ms. Stephanie Ciboroski

 Senior
Assisstant Chief Accountant

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, NE

Washington DC 20549-1090

 10 September
2012

 UBS AG

 Form 20-F
for the Fiscal Year Ended December 31, 2011

 Filed March 15, 2012

 Form 6-K

 Filed July 31, 2012

File No. 001-15060

 Dear
Ms. Ciboroski:

 We respectfully submit the responses set forth below to the comment letter dated August 10, 2012 (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, 2011 (the “2011 Form
20-F” or “AR 2011”), and (b) the second quarter 2012 report on Form 6-K (the “Q2 2012 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, 2011

Operating environment and strategy, page 15

Our strategy, page 22

We note your disclosure of your Basel III pro forma common equity ratio on page 22 as well as your pro
forma Basel III risk-weighted assets on page 25. Tell us whether these metrics are currently required to be disclosed by your home country bank regulator or securities regulator. If these metrics are not currently required to be disclosed by IFRS,
Commission Rules or banking regulatory requirements, they would appear to be non-GAAP measures. If you are unable to support that these metrics do not meet the criteria of a non-GAAP measure, please clearly label these measures as non-GAAP in your
future filings and provide the disclosures required by Item 10(e) of Regulation S-K. Refer to General Instruction C (e) of Form 20-F.

 Disclosure of our Basel III pro forma common equity ratio and risk-weighted assets is not currently required by IFRS, Commission Rules or banking regulatory requirements in Switzerland, but will be
required by the Swiss Financial Market Supervisory Authority (“FINMA”) from 1 January 2013. We include this information because it is of interest to investors in view of the impending applicability of Basel III requirements. As these
metrics are currently, and for a short time, non-GAAP measures we will clearly label them as such in our remaining filings for 2012, including our reasons for including them.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 6-K filed July 31, 2012

File No. 001-15060

 10 September 2012

 Page 2 of 28

  Comment 2

 Financial and operating performance, page 57

 Off-balance sheet, page 76

Non-consolidated securitization vehicles and collateralized debt, page 76

We note that the tabular presentation on page 77 excludes residential and commercial mortgage-backed
securities backed by a US government agency or instrumentality or US government-sponsored enterprise (i.e., GNMA, FNMA, and FHLMC). You state that such positions have been excluded due to the comprehensive involvement of the US government in these
organizations and their significantly lower risk profile. Given that the purpose of this table appears to be to quantify the extent of your involvement with non-consolidated SPEs, we are unclear as to why you would exclude US agency/GSE securities
simply due to their lower risk profile. Accordingly, please revise your future filings to quantify the extent of your involvement with all non-consolidated SPEs, including those that are backed by US agencies or GSEs. In this regard, consider
presenting US agency/GSE securities in a separate column in order to highlight their lower risk profile. As an alternative, you may also consider disclosure in the footnotes to the table.

The information provided in the table on page 77 was added to our reports in response to a specific request received in December 2007 from the Commission
to provide more information on our exposure to non-consolidated securitization vehicles and collateralized debt obligations for which UBS has material exposure. As your question states, UBS has not included information on exposures to vehicles
backed by a US government agency or instrumentality or US government sponsored entities as stated in our reports due to the comprehensive involvement of the US government in these organizations and therefore their significantly lower risk profile.

 Further information on our involvement with Securitization structures, including transactions backed by a US government agency or
instrumentality or US government sponsored entities, is, however, included in our Basel 2.5 Pillar 3 disclosures in the Risk, treasury and capital management section of our AR 2011.

 Dependent on our exposures as at the end of the year, we will add a footnote to this table either cross referring to our Basel 2.5 Pillar 3 disclosures or providing specific further information.

Comment 3

 Contractual obligations, page 79

 We note that your
contractual obligations table appears to exclude the related interest expense on your long-term debt obligations which appears to be significant based on your supplemental cash flow information disclosure of cash paid for interest during each of the
three years presented.

•

 Please revise this table in future filings to include estimated interest payments on your long-term debt and disclose any assumptions you made to
derive these amounts.

 Our current disclosure of long-term debt obligations is aligned with IFRS measurement
and presentation principles. The carrying amount of debt issued that is measured based on amortized cost generally represents the nominal amount of the respective instrument plus or minus the unamortized premium or discount. The carrying amount of
financial liabilities designated at fair value represents the fair value of the respective instruments, which includes estimated future interest payments on a discounted basis. In order to facilitate comparison to our statement of financial position
and the respective disclosure in the Notes to the Financial Statements (refer to Note 19 on page 339-340 of our AR 2011) our disclosure of long-term debt obligations within our contractual obligations disclosure is presented on the same basis.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 6-K filed July 31, 2012

File No. 001-15060

 10 September 2012

 Page 3 of 28

 In the audited section of the “Liquidity and funding management section” of our AR 2011 (refer to
pages 148-149), a maturity analysis of all financial liabilities is provided. This disclosure, as required under IFRS, generally represents undiscounted cash flows of future interest and principal payments by maturity bucket for all debt issued that
is measured at amortized cost (including short-term debt) and financial liabilities designated at fair value.

 For future filings, we will
assess how to best reflect estimated interest payments on long-term debt as part of our contractual obligations MD&A disclosure.

Comment 3, continued

•

 To the extent that you can reasonably estimate the amount and/or timing of payments that you will be obligated to make under interest rate swaps or
similar derivatives you use to manage interest rate risk related to your long-term debt, please ensure these amounts are included in the table and disclose the fact that they are considered in the obligations.

•

 To the extent that you are unable to include these derivatives in your disclosure, please clearly state that fact and provide quantification of the
amount of your long-term debt covered by these derivatives that have been excluded from the table.

 The interest rate risk of a portion of our long-term debt issued and measured on an
amortized cost basis (total position of approximately CHF 69 billion) is hedged with interest rate swaps (notional values of approximately CHF 30 billion) which are designated as hedging instruments in fair value hedges. Estimated undiscounted cash
outflows (as well as inflows) related to these swaps form an integral part of our disclosure in Note 23 of our AR 2011 (refer to page 357).

For future filings, we will assess how best to disclose in our contractual obligations MD&A disclosure the impact of interest rate swaps and similar
derivatives used to manage interest rate risk inherent in long-term debt measured on an amortized cost basis.

 Financial liabilities
designated at fair value mostly consist of structured notes and are generally also economically hedged but it would not be practicable to estimate the amount and/or timing of the payments on interest swaps used to hedge these instruments, as
interest rate risk inherent in respective liabilities is generally risk managed on a portfolio level. We will clarify this fact in our future filings.

Comment 3, continued

•

 Finally, to the extent that you have excluded certain types of interest payments from the table, such as for structured notes where payment obligations
are based on the performance of certain benchmarks or variable rate debt, please provide quantification of the amount of long-term obligations that have these types of interest rates and thus have been excluded from the table.

 As referenced above, our disclosure of long-term debt obligations for financial
liabilities designated at fair value represents the fair value of the respective instruments which includes estimated future interest payments on a discounted basis. In future filings, we will quantify the amount of long-term debt obligations which
have variable payment obligations.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 6-K filed July 31, 2012

File No. 001-15060

 10 September 2012

 Page 4 of 28

  Comment 4

 Risk, treasury and capital management, page
111

 Credit risk, page 116

Composition of credit risk – UBS Group, page 118

We note that you excluded portfolio hedges, such as index CDS, from your credit risk disclosures on
pages 119 and 122. Please tell us and revise your disclosure in future filings to explain why you have excluded such hedges from your credit exposure analysis. Please also provide some context around the types of portfolio hedges that you enter into
and how these hedges impact your overall credit risk exposure.

 The credit risk arising from portfolio hedges such as Index CDS is
included within the figures presented but the risk reducing effect of such hedges on other credit risk exposures (e.g. loans) is not. This is because the hedges cannot be apportioned to individual exposures but rather act as macro hedges to combined
portfolios. We recognize that this is not clear from our existing MD&A comments and will revise our disclosure in future filings to make our approach clearer.

Comment 5

 Composition of credit risk – business divisions, page 120

 Wealth Management & Swiss Bank, page 120

 We note
your disclosure that approximately 75% of Wealth Management & Swiss Bank’s loan portfolio is secured by real estate and that the majority of this real estate exposure is secured by Swiss residential property, which has typically
exhibited a low risk profile. We further note your disclosures on pages 117 – 118 that state that loan-to-value (LTV) ratios are a key factor in both your probability of default and loss given default measures. Given the importance of LTV
ratios in your assessment of credit risk within your residential real estate loan portfolio, we believe that additional disclosure around these measures is warranted, particularly given recent concerns over a potential future housing price
correction in Switzerland. Accordingly, please revise your future filings as follows:

•

 Describe your underwriting standards for residential real estate loans, including whether you have strict guidelines concerning LTV ratios at
origination. If possible, disclose the average LTV ratio at origination for this portfolio.

•

 Provide quantitative information reflecting the current LTV ratios for your residential real estate loan portfolio. In this regard, consider providing
a breakdown of this portfolio by LTV bucket (100% +, 80%–100%, and below 80%).

•

 Describe how current LTV ratios are calculated for your residential real estate portfolio (e.g., whether they are based on updated appraisals, housing
price indexes or a combination thereof).

 An overview of the LTV ratio of this portfolio was provided on
slide 22 of our Q2 results presentation that was submitted to the Commission on Form 6-K on 31st July 2012. We will expand our 2012 year-end disclosure to more broadly address the three bullets above.

Comment 6

We note your disclosure on page 120 that the significant shift in your net banking products exposure
from sub-investment grade to investment grade in 2011 was mainly due to the introduction of a new rating methodology for the retail mortgage segment. Please tell us and revise your disclosure in future filings to describe in more detail the changes
that were made to your

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 6-K filed July 31, 2012

File No. 001-15060

 10 September 2012

 Page 5 of 28

 ratings methodology. In this respect, clarify whether there was any actual improvement in credit quality and if not, the primary reasons for the improved ratings under your revised methodology. Please
also describe the extent to which your revised rating methodology impacted your allowance for loan losses and provide quantification of the impact of this change, if practicable.

 The changes that were made to our ratings methodology enhanced our approach from one that was based primarily on Loan to Value (“LTV”) and Exposure at Default (“EAD”) parameters to one
that also takes into account additional factors such as client behavior, the time elapsed since the last mortgage arrears and the maximum length of mortgage arrears. This change in methodology was the primary driver for the improved ratings. We will
describe material changes in rating methodology in more detail going forward.

 Allowances for loan losses were not impacted by this change in
methodology.

Comment 7

 Investment Bank, page 122

 Loan to BlackRock Fund, page
123

 On page 124 you indicate that developments through the year ended December 31,
2011 did not alter your conclusion that the loan to the BlackRock Fund is not impaired and that consolidation is not required. Please tell us the developments you considered in forming your conclusion.

On a monthly basis we receive updated market values for the underlying assets from BlackRock Financial Management, Inc and a cash collection schedule,
and we monitor delinquencies and other real estate owned foreclosures to ensure that the loan is being paid down and that there are no indications of impairment. UBS checks the fair values received using its own model and in addition applies a
number of stress scenarios where we make adverse assumptions regarding future home prices.

 By 31 December 2011, UBS’s loan had been
paid down by 58%, with cash collections continuing to be effective in paying down the loan balance. In addition, the stress scenarios applied support the view that UBS’s loan is highly likely to be repaid.

Under current accounting requirements, generally, we will consolidate when UBS absorbs a majority of the risk arising in a vehicle or UBS has control
through having substantive and beneficial decision rights. We continue not to consolidate the fund as the fund’s equity holders absorb the majority of risk arising in the fund and UBS has no direct or indirect voting or decision making powers,
with the General Partner of the fund—a Black