SecProbe.io

CORRESP
 1
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 CORRESP

 UBS Group AG
 Bahnhofstrasse 45, 8001 Zurich,
Switzerland UBS AG
 Bahnhofstrasse 45, 8001 Zurich,
Switzerland Aeschenvorstadt 1,
 4051 Basel, Switzerland UBS
Americas Inc. 11 Madison Avenue
 New York, NY 10010
 February 17, 2026 Via EDGAR
 U.S. Securities and Exchange Commission
 Division of Corporation Finance,
 100 F Street, N.E., Washington,
D.C. 20549.

 Attention:

 Madeleine Joy Mateo

 Re:

 UBS Group AG, UBS AG and UBS Americas Inc.
 Registration Statement on Form F-3
 File No. 333-293403
 Dear Ms. Mateo:
 Pursuant to Rule 461 under the Securities Act of 1933, as amended, UBS Group AG, UBS AG and UBS Americas Inc. hereby respectfully request that
the effectiveness of the above-referenced Registration Statement on Form F-3 be accelerated so that it will be declared effective at 4:30 p.m. (EST), on February 19, 2026, or as soon as practicable
thereafter, unless UBS Group AG, UBS AG or UBS Americas Inc. notifies you otherwise prior to such time. *  *   *

 U.S. Securities and Exchange Commission

 -2-
 Please do not hesitate to contact John Horsfield-Bradbury of Sullivan & Cromwell LLP
by telephone (+44 20 7959 8491) or email ( horsfieldbradburyj@sullcrom.com ) with any questions or comments regarding this filing.
 In addition, please inform Mr. Horsfield-Bradbury when this request for acceleration has been granted.
 Very truly yours,

 -3-

 UBS Group AG

 By:

 /s/ David Kelly

 Name:

 David Kelly

 Title:

 Managing Director

 By:

 /s/ Ella Copetti-Campi

 Name:

 Ella Copetti-Campi

 Title:

 Executive Director

 UBS AG

 By:

 /s/ David Kelly

 Name:

 David Kelly

 Title:

 Managing Director

 By:

 /s/ Ella Copetti-Campi

 Name:

 Ella Copetti-Campi

 Title:

 Executive Director

 UBS Americas Inc.

 By:

 /s/ Patrick Shilling

 Name:

 Patrick Shilling

 Title:

 Managing Director

 By:

 /s/ Maria Chiodi

 Name:

 Maria Chiodi

 Title:

 Managing Director

 cc:
 John Horsfield-Bradbury
 (Sullivan & Cromwell LLP)

January 12, 2026
Sergio P. Ermotti
Chief Executive Officer
UBS Group AG
Bahnhofstrasse 45
8001 Zurich, Switzerland
Re:UBS Group AG
Draft Registration Statement on Form F-3
Submitted January 7, 2026
CIK No. 0001610520
Dear Sergio P. Ermotti:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement and non-public draft
submission on EDGAR at least two business days prior to the requested effective date and
time. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Tonya Aldave at 202-551-3601 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:John Horsfield-Bardbury, Esq.

November 17, 2025
Todd Tuckner
Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland
Re:UBS AG
Form 20-F for Fiscal Year Ended December 31, 2024
File No. 001-15060
Dear Todd Tuckner:
            We have completed our review of your filing. We remind you that the company and
its management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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secletterubsag2025101

UBS AG

Postfach

8098 Zürich

Todd Tuckner

UBS AG Chief Financial Officer

Tel. +41-44 236 8600

Todd.tuckner@ubs.com

www.ubs.com

Ms. Cara Lubit and Mr. Robert Klein

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington DC 20549-1090

October 10, 2025

UBS AG

Form 20-F for the Fiscal Year Ended December 31, 2024

Filed March 17, 2025

File No. 001-15060

Dear Ms. Cara Lubit and Mr. Robert Klein,

We have reviewed the comments

raised in the Comment

Letter dated September

12, 2025 from the

Staff of the Securities and Exchange Commission relating to the annual report on Form 20-F for the

fiscal

year

ended

December

31,

2024.

For

your

convenience,

we

have

set

out

the

text

of

each

Comment contained in the Comment Letter, followed by our responses.

Alternative performance measures, page

2

We note your disclosure, here and elsewhere,

that your alternative performance measures

("APMs")

may

qualify

as

non-GAAP

measures.

In

future

filings,

please

clearly

identify

all

APMs

that

are

considered to

be non-GAAP

financial measures

and to

the extent

that they

continue to

be presented,

ensure

that

you

provide

required

disclosures,

including

a

reconciliation,

under

Regulation

G

and

under Item 10(e) of Regulation S-K, as applicable.

UBS response:

In future filings, we

will clearly identify

all non-GAAP measures

and include a reference

to where the

required disclosure and reconciliation is presented in the filing.

The APM definition under Swiss

regulations is significantly broader than the

definition of non-GAAP

financial measures in Regulation

S-K, and hence not

all APMs used by

us are non-GAAP

measures.

For example, “cost/income

ratio” calculated as “operating

expenses divided by total

revenues” is an

APM for purposes

of the Swiss

rules (as it is

a ratio of

two required measures) but

is not a non-GAAP

financial measure.

With respect

to

Regulation G,

we

note

that

UBS

meets the

exemptive

criteria for

foreign

private

issuers.

UBS AG

Postfach

8098 Zürich

Todd Tuckner

UBS AG Chief Financial Officer

Tel. +41-44 236 8600

Todd.tuckner@ubs.com

www.ubs.com

1

UBS AG consolidated performance, page

68

We note your

disclosure, here

and on page

173, that

Portfolio management

and related services

and

Investment fund

fees totaled

$11,328 million

and $5,669

million for

2024, respectively,

and that

they are

predominantly in

Global Wealth

Management

and Asset

Management,

respectively. We also

note

your

disclosure

on

page

266

that

Recurring

net

fee

income

includes

these

revenues.

Please

expand your disclosure in future filings,

here or elsewhere as appropriate, for the

following items:

a.

Discuss

the

nature

of

these

revenue

streams

and

services,

and

describe

any

material

arrangement terms, such

as fee structure

and fee

rates. If applicable,

explain the correlation

of invested

assets and

fee-generating assets

to the

corresponding revenue

line items

at AG

and business division levels.

b.

Disclose

how

Portfolio

management and

related

services and

Investment

fund

fee

revenue

amounts

reconcile

to

the

Recurring

net

fee

income

and/or

any

other

applicable

business

division line amounts presented on pages 44 and

47.

c.

To the extent that revenue

line items at

AG or business

division levels are

impacted by

multiple

change drivers, expand your

discussion of period-over-period changes

to quantify the impacts

of each

material factor (e.g.,

acquisition, change in

invested asset

mix, fee

rate movements,

etc.).

UBS response:

UBS discloses

revenues in its

MD&A in

categories, including

recurring income

and transaction

income

for Global Wealth

Management and

Personal and

Corporate Banking

and net management

fees and

performance fees

for Asset

Management to

provide

investors with

a

better understanding

of the

most important

revenue sources

in these

divisions and

to facilitate

discussion in

the MD&A

of the

key drivers

affecting business

division results.

Definitions of

these measures

are included

in the

MD&A

and the table of Alternative

Performance Measures included

in the Annual Report.

This disclosure is

aligned with how management assesses business

performance.

With respect to the specific comments:

a.

In future Annual Reports, UBS will

expand its discussion of

products, services and fee structures

for each business division in “Our strategy, business model and environment” section.

b.

The

MD&A

discussion

of

net

fee

and

commission

income

in

the

“UBS

AG

consolidated

performance” section

of

the

MD&A

on

page

39

is

based

on

the

breakdown of

net

fee

and

1

Recurring

net

fee

income

of

GWM

includes

”fees

for

services

provided

on

an

ongoing

basis,

such

as

portfolio

management fees,

asset-based investment

fund fees

and custody

fees, which

are

generated on

client assets,

and

administrative fees for accounts.” Transaction-based income of GWM includes “the non-recurring portion of net fee

and commission income, mainly

composed of brokerage and

transaction-based investment fund fees,

and credit card

fees, as well as

fees for payment and foreign

-exchange transactions, together with other

net income from financial

instruments measured at fair value through profit or loss”.

Asset Management

net management fees,

includes fund

management fees,

and transaction

fees, fund

administration

revenues (including net interest and trading income from lending activities

and foreign-exchange hedging as part of

the fund services offering),

distribution fees, incremental fund-related expenses,

gains or losses

from seed money and

co-investments, funding

costs, the

negative pass-through

impact of

third-party performance

fees, and

other items

that are not Asset Management’s performance fees

UBS AG

Postfach

8098 Zürich

Todd Tuckner

UBS AG Chief Financial Officer

Tel. +41-44 236 8600

Todd.tuckner@ubs.com

www.ubs.com

commission

income

that

is

disclosed

in

Note

5

to

the

financial

statements

in

line

with

the

requirements

under

IFRS

15

Revenue

from

Contracts

with

Customers

and

IFRS

8

Operating

Segments

. In addition to

Global Wealth Management,

Personal & Corporate

Banking and Asset

Management,

our

UBS

AG

consolidated

performance

disclosure

also

includes

amounts

attributable to the Investment Bank

and Non-core & Legacy

performance segments, as well as

Group

Items. A

breakdown of

third-party

fee and

commission income

by business

division is

provided in the footnotes to the table in Note 5 to

the financial statements.

The information provided in the MD&A discussion for Global Wealth Management, Personal &

Corporate

Banking

and

Asset

Management

regarding

recurring,

transaction-based,

management

and

performance

fees

is

based

on

the

same

amounts

and

business

division

allocation as set

forth in Note

5 to the

financial statements, but is

presented on a

“net basis”

(that

is,

after

deduction

of

Fee

and

commission

expense,

defined

in

Note

1

to

the

financial

statements

Summary of material accounting policies

as “expenses that are directly attributable

to

the

satisfaction

of

specific

performance

obligations

associated

with

the

generation

of

revenues”) since that is the

information used by management

in evaluating the performance

of

those divisions.

In future

filings we

will add

disclosure to

more fully

explain the

UBS AG

performance MD&A

disclosure

of

fee

and

commission

income,

with

reference

to

the

discussion

of

recurring,

transaction-based, management and

performance fees in

the MD&A

discussion of

the Global

Wealth Management, Personal &

Corporate Banking and Asset

Management business divisions

and to the net fee and commission income disclosed

in Note 5 to the financial statements.

c.

To

the extent that revenue line items at the UBS AG or business division levels are impacted by

multiple change

drivers, we

will enhance

our disclosure

of period-over-period

changes

to provide

further

quantitative

disclosures

for

each

material

driver

that

would

enhance

an

investor’s

understanding of

our results

and are

reflective

of information

that management

considers in

understanding revenue changes.

Please do not hesitate to contact either Todd Tuckner at +41 44 236 8600 (

todd.tuckner@ubs.com

)

or Dominique Crowe at +44 207 567 8158

(

dominique.crowe@ubs.com

) if you have any questions

or require additional information.

Yours faithfully,

UBS AG

/s/ Todd

Tuckner

/s/ Dominique Crowe

Todd

Tuckner

Dominique Crowe

UBS AG Chief Financial Officer

UBS AG Chief Accounting Officer

September 12, 2025
Todd Tuckner
Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland
Re:UBS AG
Form 20-F for Fiscal Year Ended December 31, 2024
Filed March 17, 2025
File No. 001-15060
Dear Todd Tuckner:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2024
Alternative performance measures, page 2
1.We note your disclosure, here and elsewhere, that your alternative performance
measures ("APMs") may qualify as non-GAAP measures. In future filings,
please clearly identify all APMs that are considered to be non-GAAP financial
measures and to the extent that they continue to be presented, ensure that you provide
required disclosures, including a reconciliation, under Regulation G and under Item
10(e) of Regulation S-K, as applicable.
UBS AG consolidated performance, page 39
We note your disclosure, here and on page 173, that Portfolio management and related
services and Investment fund fees totaled $11,328 million and $5,669 million for
2024, respectively, and that they are predominantly in Global Wealth Management
and Asset Management, respectively. We also note your disclosure on page 266 that
Recurring net fee income includes these revenues. Please expand your disclosure in 2.

September 12, 2025
Page 2
future filings, here or elsewhere as appropriate, for the following items:
•Discuss the nature of these revenue streams and services, and describe any
material arrangement terms, such as fee structure and fee rates. If applicable,
explain the correlation of invested assets and fee-generating assets to the
corresponding revenue line items at AG and business division levels.
•Disclose how Portfolio management and related services and Investment fund fee
revenue amounts reconcile to the Recurring net fee income and/or any other
applicable business division line amounts presented on pages 44 and 47.
•To the extent that revenue line items at AG or business division levels are
impacted by multiple change drivers, expand your discussion of period-over-
period changes to quantify the impacts of each material factor (e.g., acquisition,
change in invested asset mix, fee rate movements, etc.).
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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CORRESP

 UBS AG

Bahnhofstrasse 45,

 8001 Zurich,
Switzerland

 UBS Switzerland AG

Bahnhofstrasse 45,

 8001 Zurich,
Switzerland

 February 4, 2025  

VIA EDGAR AND E-MAIL

U.S. Securities and Exchange Commission

Division of Corporation Finance,

100 F Street, N.E.,

 Washington,
D.C. 20549.

Attention:
  Robert Arzonetti

Re:
 UBS AG and UBS Switzerland AG (the “Registrants”)

 
 Registration Statement on Form F-3 (File No. 333-283672 and 333-283672-01)

Ladies and Gentleman:

 With respect to the
above-referenced registration statement (the “Registration Statement”), and pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, we hereby respectfully request that the Securities and Exchange
Commission (the “Commission”) accelerate the effective date of the Registration Statement so that it is declared effective at 4:30 p.m. (EST), on February 6, 2025, or as soon as practicable thereafter.

Please contact Catherine M. Clarkin of Sullivan & Cromwell LLP, U.S. counsel to the Registrants, at (212) 558-4175 or by email (clarkinc@sullcrom.com), as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Securities and Exchange Commission

Page 2

 Thank you for your assistance in this matter.

Yours truly,

UBS AG

UBS SWITZERLAND AG

 /s/ David Kelly

Name: David Kelly

Title:  Managing Director

 /s/ Patrick T. Shilling

Name: Patrick T. Shilling

Title:  Managing Director

cc:

 Catherine M. Clarkin

 (Sullivan &
Cromwell LLP)

December 18, 2024
Sergio P. Ermotti
Group Chief Executive Officer
UBS AG
Bahnhofstrasse 45, 8001 Zurich
Switzerland, +41 44 234 11 11
Re:UBS AG
Registration Statement on Form F-3
Filed December 6, 2024
File No. 333-283672
Dear Sergio P. Ermotti:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Robert Arzonetti at 202-551-8819 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Cathy Clarkin

CORRESP
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CORRESP

 UBS AG

Bahnhofstrasse 45,

 8001 Zurich,
Switzerland

 VIA EDGAR AND E-MAIL

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

 Washington,
DC 20549

 May 28, 2024

Attention:

Christian Windsor

Robert Arzonetti

Re:

UBS AG

Registration Statement on Form F-3

File No. 333-278934

 Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we
hereby request acceleration of the effective date of the Registration Statement on Form F-3/A (File No. 333-278934) (the “Registration
Statement”) of UBS AG. We respectfully request that the Registration Statement become effective as soon as possible after effectiveness of the merger by absorption under Swiss law (Absorptionsfusion) whereby Credit Suisse AG
(including its branches) will be absorbed by UBS AG (the “Merger”). It is expected that the Merger will become effective on May 31, 2024 (the “Effective Date”) and when it has become effective, our counsel,
Sullivan & Cromwell LLP, will confirm this orally to you on the Effective Date. We request that the Registration Statement be declared effective by oral confirmation as soon as possible thereafter via confirmation to Sullivan &
Cromwell LLP.

 Please contact Catherine M. Clarkin of Sullivan & Cromwell LLP via telephone at (212) 558-4175 or via e-mail at (clarkinc@sullcrom.com) with any questions about this request.

[signature page follows]

 Thank you for your assistance in this matter.

Very truly yours,

UBS AG

By:

 /s/ David Kelly

Name:

David Kelly

Title:

Managing Director

By:

 /s/ Patrick T. Shilling

Name:

Patrick T. Shilling

Title:

Managing Director

cc:

Catherine M. Clarkin

(Sullivan & Cromwell LLP)

United States securities and exchange commission logo
May 3, 2024
Sergio P. Ermotti
Chief Executive Officer
UBS AG
Bahnhofstrasse 45
8001 Zurich
Switzerland
Re:UBS AG
Registration Statement on Form F-3
Filed April 25, 2024
File No. 333-278934
Dear Sergio P. Ermotti:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Robert Arzonetti at 202-551-8819 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Ethan J. Chess

CORRESP
1
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UBS AG

Bahnhofstrasse 45,

8001 Zurich, Switzerland

September 11, 2023

Via EDGAR

    United States Securities and Exchange Commission,

    Division of Corporation Finance,

    Office of Manufacturing,

    100 F Street N.E.,

    Washington, D.C. 20549.

    Attention:

    Ms. Adegbuyi

    Re:

    UBS AG

    Registration Statement on Form F-4

    File No. 333- 274180

Dear Ms. Adegbuyi:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended, UBS AG hereby respectfully requests that the effectiveness of the above-referenced Registration Statement on Form F-4 be accelerated
so that it will be declared effective at 12 p.m. Eastern Time on September 13, 2023, or as soon as practicable thereafter, unless UBS AG
notifies you otherwise prior to such time.

*	*	*

U.S. Securities and Exchange Commission

-2-

Please do not hesitate to contact John Horsfield-Bradbury
of Sullivan & Cromwell LLP by telephone (+44 20 7959 8491) or email (horsfieldbradburyj@sullcrom.com)
with any questions or comments regarding this filing.

In addition, please inform Mr. Horsfield-Bradbury
when this request for acceleration has been granted.

    Very truly yours,

    UBS AG

    By:
    /s/ David Kelly

    Name:
    David Kelly

    Title:

    Managing Director

    By:
    /s/ Ella Campi

    Name:
    Ella Campi

    Title:

    Executive Director

    cc:
    Federica Pisacane-Rohde

    (UBS AG)

    John Horsfield-Bradbury

    (Sullivan & Cromwell LLP)

CORRESP
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CORRESP

 [UBS AG Letterhead]

May 25, 2022

 VIA EDGAR

Mr. John Dana Brown,

 Division of
Corporation Finance,

 Securities and Exchange Commission,

100 F Street, N.E.,

Washington, D.C. 20549.

Re:
 UBS AG and UBS Switzerland AG (the “Registrants”)

Registration Statement on Form F-3 (File
No. 333-263376)

 Dear Mr. Brown:

With respect to the above-referenced registration statement (the “Registration Statement”), and pursuant to Rule 461 of Regulation C
promulgated under the Securities Act of 1933, as amended, we hereby respectfully request that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the Registration Statement so that it is declared
effective at 4:30 p.m. (EST), on May 27, 2022, or as soon as practicable thereafter.

 Please contact Catherine M. Clarkin of
Sullivan & Cromwell LLP, U.S. counsel to the Registrants, at (212) 558-4175 or by email (clarkinc@sullcrom.com), as soon as the Registration Statement has been declared effective, or if you
have any other questions or concerns regarding this matter.

 Mr. John Dana Brown

Securities and Exchange
Commission

              Page 2

 Yours truly,

 UBS AG

UBS SWITZERLAND AG

/s/ David Kelly

 Name: David Kelly

 Title: Managing Director

 /s/ Ella Campi

 Name: Ella Campi

 Title: Executive Director

cc:

 Catherine M. Clarkin

 (Sullivan &
Cromwell LLP)

United States securities and exchange commission logo
March 16, 2022
Ralph A.J.G. Hamers
Group Chief Executive Officer
UBS AG
Bahnhofstrasse 45, CH-8001
Zurich, Switzerland
Re:UBS AG
Registration Statement on Form F-3
Filed March 9, 2022
File No. 333-263376
Dear Mr. Hamers:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact John Dana Brown at 202-551-3859 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

September 19, 201 9
Via E-mail
Kirt Gardner
Chief Financial Officer
UBS Group AG
Bahnhofstrasse 45, CH -8001
Zurich
Switzerland

 Re: UBS Group AG
  UBS AG
  Form s 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 15 , 2019
  File No s. 1-36764 and 1 -15060

Dear Mr. Gardner :

We refer you to our comment letter  dated  September 3, 2019  regarding business contacts
with Syria and Sudan .  We have completed our review of this subject matter.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff .

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Todd Tuckner , Controller
  UBS Group AG

  Pamela Long
  Assistant Director

CORRESP
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ubsgroupag.20f.ogsr.letter

UBS Group  AG

UBS AG

Postfach

8098 Zürich

Group
CFO

Kirt
Gardner

Tel: +41-44-237-3791

kirt.gardner@ubs.com

Group Controller  and  Chief  Accounting  Officer

Todd Tuckner

Tel: +203-719-0381

todd.tuckner@ubs.com

www.ubs.com

Ms. Cecilia Blye, Chief

Office of  Global  Security Risk

Securities and Exchange Commission

100 F
Street, NE

Washington DC 20549-1090

Re:       UBS Group AG

            UBS AG

Form 20-F for the Fiscal Year  Ended  December  31,  2018

Filed March 15,  2019

File Nos.  1-36764
and  1-15060

September 17,  2019

Dear Ms.  Blye,

We respectively  submit  a  response  to  your  letter  dated  September  3,  2019  from  the  staff  of  the  Securities  and  Exchange
Commission  relating  to  Form  20-F  for  the  Fiscal  Year  Ended  December  31,  2018,  filed  March 15,
2019.

1.
Please  describe  to  us  the  nature  and  extent  of  any  past,  current,  and  anticipated  contacts  with  Syria  and  Sudan  since  our  2016  review,  including
contacts  with  those  countries'  governments,  whether  through  subsidiaries,  affiliates,  or  other  direct  or  indirect  arrangements.
  As
you  are  aware,  Syria  and  Sudan  are  designated  by  the

U.S. Department  of  State  as  state  sponsors
of  terrorism  and  are  subject
to  U.S.  economic  sanctions  and/or  export  controls.  Your  Form  20-F  does  not  provide
disclosure about those
countries.

UBS has  no  past,  current,  or  anticipated  contact  with  the  Subject  Countries,  either  directly
or  through  subsidiaries,  affiliates,  customers  or  direct  or  indirect  arrangements,  apart  from  those  that  may  be  licensed
or  otherwise  permitted
by  the  U.S.  Department  of  the  Treasury,
Office  of  Foreign
Assets  Control  ("OFAC")  as set  forth below  in  response
to SEC Question 2.

UBS Group  AG  and  UBS  AG  ("UBS"  or  the  "Bank")  do  not  have  a  subsidiary  or  affiliate,  employees,  or  other  physical
presence  in  either
Syria  or  Sudan  (the  "Subject  Countries").  UBS  maintains
a  Group  Sanctions
Policy  (the  "Policy")  that  prohibits  transactions  involving  Syria  and  transactions  involving  the  Government  of  Sudan.  Pursuant
to  the  Policy,  UBS  restricts
dealings  with  clients  where  the  Bank  could  provide  benefit  to  the  foregoing.  UBS's  know-your-customer  policies  also  require  that  additional  inquiries  be  made  where  there  are  indications  that  a  client  has  dealings  in  or  with  a  sanctioned  country  or government.
The Bank's  systems  and controls  are  designed
to  prevent

Page 2

transactions involving  the  Subject  Countries  and  sanctioned  parties.  Additionally,  the  Bank  performs  periodic  reviews  of  our  clients  to  ensure  that  any  new  potential  risks  are  identified  and  promptly  addressed.  These
systems, controls,
and reviews are
subject to regular audit  and  testing.

2.
Please  discuss  the  materiality  of  any  contacts
with  Syria  and  Sudan  in  quantitative  terms  and  in  terms  of  qualitative  factors  that  a  reasonable  investor  would  deem  important  in  making  an  investment  decision.  Tell  us  the  approximate  dollar  amounts  of  any  revenues,
assets  and  liabilities  associated  with  those  countries  for  the  last  three  fiscal  years  and  the  subsequent  interim  period.  Address  for  us  the  potential
impact  of  the  investor
sentiment  evidenced  by  divestment  and  similar
initiatives  that  have  been  directed  toward  companies  that  have  operations  associated
with state sponsors of  terrorism.

We do  not  believe  that  any  activities  involving  the  Subject  Countries,  individually  or  in  the  aggregate,  constitute  a  material
risk  to  our  security
holders.  UBS  has  no  relationships  with  the  governments,  state-owned  enterprises,  or  banks  of  the  Subject
Countries.  UBS  AG  and  UBS  Switzerland  AG  hold  a  small  number  of  legacy  private  accounts  for  persons  domiciled  in  Syria  with  whom  it  transacts
in  accordance  with  a  specific  OFAC  license.  Sudan  is  no  longer  subject
to  comprehensive  U.S.  sanctions  and  accordingly  the  Bank’s  small  number  of  relationships  with  those  domiciled  in  Sudan  (e.g.  international  organization  employees  on  mission)
do  not  require  OFAC  general
or specific
licensing.

Below is  information  concerning  UBS's  global  exposure  to  Sudan  and  Syria.  We  consider
our  exposure  to  these  Subject
Countries  to  be  immaterial  relative  to  our  overall  business
and  in  compliance with sanctions requirements  as  explained in the paragraph above:

  USD

  31-Dec-16

  31-Dec-17

  31-Dec-18

  30-Jun-19

  Sudan

  Syria

  Sudan

  Syria

  Sudan

  Syria

  Sudan

  Syria

  Revenues

  14,608

  78,710

  26,067

  149,150

  23,788

  118,254

  23,357

  45,542

  Client Assets

  2,054,376

  11,688,267

  2,078,920

  9,677,352

  4,028,235

  10,605,347

  5,094,351

  9,759,079

  Assets

  3,000

  28,000

  5,000

  10,000

  248,000

  804,000

  2,000

  810,000

  Liabilities

  -
  2,118,000

  -
   5,090,000

  -  1,853,000

  -
  4,016,000

  -  1,701,000

  -
   4,434,000

  -  2,391,000

  -  4,322,000

With respect  to  various  US  state  divestment  laws  or  similar  initiatives  that  require  divestment  from,  or  reporting
of  interests  in,  companies
that  do  business  with  state  sponsors
of  terrorism,  we  believe
that  our  Group  Sanctions
Policy  and  relevant
systems  and  controls
are  appropriately  designed  to  comply  with  US  sanctions
globally  and  thus  prevent  the  underlying  activity  that  would  trigger  concerns  from  a  divestment perspective.

We appreciate  the  opportunity  to  provide  you  with  this  additional  information.  If you  wish  to  discuss  any  of  our  responses
or  require  further
information,  please  do  not  hesitate  to  contact  Todd  Tuckner  at  +1  203-719-0381 (todd.tuckner@ubs.com).

Yours sincerely,

UBS Group AG

/s/ Kirt  Gardner                                                    /s/ Todd
Tuckner

Kirt Gardner                                                       Todd
Tuckner

Group Chief Financial  Officer                                Group
Controller and Chief
Accounting Officer

September 3 , 201 9
Via E-mail
Kirt Gardner
Chief Financial Officer
UBS Group AG
Bahnhofstrasse 45, CH -8001
Zurich
Switzerland

 Re: UBS Group AG
  UBS AG
  Form s 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 15 , 2019
  File No s. 1-36764 and 1 -15060

Dear Mr. Gardner :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and  we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand y our disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell  us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. Please describe to us the nature and extent of any past, current, and anticipated contacts
with Syria and Sudan since our 2016 review , including contacts with those countries’
governments, whether through subsidiaries, affiliates, or other direct or indirect
arrangements.  As you are aware, Syria and Sudan are designated by the U.S. Department
of State as state sponsors of terrorism and  are subject to U.S. economic sanctions and/or
export controls.  Your Form 20 -F does not provide disclosure about those countries.

2. Please discuss the materiality of any contacts with Syria and Sudan in quantitative terms
and in terms of qualitative fact ors that a reasonable investor would deem important in
making an investment decision.  Tell us the approximate dollar amounts of any revenues,
assets and liabilities associated with those countries for the last three fiscal years and the

Kirt Gardner
UBS Group AG
 September 3 , 2019
 Page 2

 subsequent interim period.  Address for us the potential impact of the investor sentiment
evidenced by divestment and similar initiatives that have been directed toward companies
that have operations associated with state sponsors of terrorism.

We urge  all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or m e at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Todd Tuckner , Controller
  UBS Group AG

  Pamela Long
  Assistant Director

CORRESP
1
filename1.htm

CORRESP

 [UBS AG Letterhead]

October 29, 2018

 VIA EDGAR

Ms. Era Anagnosti,

 Legal Branch Chief,
Office of Financial Services,

 Division of Corporation Finance,

Securities and Exchange Commission,

100 F Street, N.E.,

Washington, D.C. 20549.

 Re:
   UBS AG and UBS Switzerland AG (the “Registrants”)

 Registration Statement on Form F-3 (File No. 333-225551)

 Dear Ms. Anagnosti:

 With respect to the above-referenced registration statement (the “Registration Statement”), and pursuant to Rule 461 of
Regulation C promulgated under the Securities Act of 1933, as amended, we hereby respectfully request that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the Registration Statement so that it is
declared effective at 4:20 p.m. (EST), on October 31, 2018, or as soon as practicable thereafter.

 Please contact Catherine M.
Clarkin of Sullivan & Cromwell LLP, U.S. counsel to the Registrants, at (212) 558-4175 or by email (clarkinc@sullcrom.com), and Steven J. Borenstein at (212)
558-3055 or by email (borensteins@sullcrom.com), as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Yours truly,

UBS AG

UBS SWITZERLAND AG

 /s/ David Kelly

 Name: David Kelly

 Title:   Managing Director

 cc: Catherine M. Clarkin

     Steven J. Borenstein

     (Sullivan & Cromwell LLP)

CORRESP
1
filename1.htm

CORRESP

 [Sullivan & Cromwell LLP Letterhead]

August 17, 2018

 VIA EDGAR
CORRESPONDENCE

 Ms. Era Anagnosti,

    Legal Branch Chief, Office of Financial Services,

        Division of Corporation Finance,

            Securities and Exchange Commission,

                100 F Street, N.E.,

                    Washington, D.C. 20549.

Re:
 UBS AG and UBS Switzerland AG Registration Statement on Form F-3

 Filed June 11, 2018

 File Nos. 333-225551 and
333-225551-01

Dear Ms. Anagnosti:

 On behalf of our
clients, UBS AG, a corporation organized under the laws of Switzerland (the “Company”), and UBS Switzerland AG, a corporation organized under the laws of Switzerland (“UBS Switzerland” and, together with the Company,
“UBS”), below are responses to the oral comments my colleague and I received from Mr. David Lin, a member of the staff (“Staff”) of the Securities and Exchange Commission (“SEC”), with respect to the
above-referenced Registration Statement (the “Registration Statement”).

 For convenience of reference, each Staff comment is
summarized below and is followed by the corresponding response of UBS.

*    *    *    *    *

Comment No. 1

 Please clarify whether the
Registration Statement is intended to register Units. Note the statement on page 12 of the Company’s prospectus that “We may issue debt securities separately or together with other debt securities or with our warrants.”

Response to Comment No. 1

Neither the Company nor UBS Switzerland is registering Units on the Registration Statement. In
Pre-Effective Amendment No. 1 to the Registration Statement (“Amendment No. 1”), UBS will revise the second paragraph under “Description of Debt Securities We May Offer—We May
Issue Many Series of Debt Securities Under the Debt Indenture” of each prospectus to delete any reference to issuing debt securities together with warrants. The relevant sentence in each prospectus will be revised to read that “We may
issue debt securities separately or together with other debt securities.”

 Ms. Era Anagnosti

 Securities and Exchange
Commission

Page 2

Similarly, UBS will revise the second sentence under “Description of Warrants We May Offer—We May Issue Many Series of Warrants”
of each prospectus to delete any reference to debt securities and the revised sentence will provide that “We may offer warrants separately or together with other warrants.”

Comment No. 2

 Please provide us
with your analysis on UBS Switzerland’s eligibility to register securities on Form F-3.

 Response
to Comment No. 2

 Background

For Swiss regulatory purposes, on June 14, 2015, the Company transferred the Swiss-booked business of its Retail & Corporate
business division and Wealth Management business division to UBS Switzerland. In connection with the asset transfer, UBS Switzerland became a co-obligor on the Company’s outstanding registered debt
securities and warrants outstanding on such date (the “Outstanding Securities”).1 Following the transfer, UBS Switzerland has not issued, and does not plan to issue, any SEC-registered securities. As set forth in note (4) to the fee table, the Registration Statement only registers existing, outstanding UBS Switzerland securities for market-making purposes and does not register
any new securities that may be issued by UBS Switzerland in the future.

 Analysis

General Instruction I.A.5. to Form F-3 sets forth the conditions pursuant to which securities of a
“majority-owned subsidiary” may be registered on Form F-3 and clause (iv) of such instruction provides that the securities of the majority-owned subsidiary may be registered on Form F-3 if (1) the parent of the subsidiary meets the “Registrant Requirements” set forth under General Instruction I.A. of Form F-3 and the applicable transaction
requirement under Form F-3, and (2) the securities of the majority-owned subsidiary being registered are full and unconditional guarantees, as defined in Rule 3-10
of Regulation S-X, of the payment obligations of the parent’s non-convertible securities, other than common equity, being registered.

Here, UBS Switzerland is a wholly-owned subsidiary of the Company and the Company meets the Registrant Requirements and the applicable
transaction requirement of Form F-3. In addition, UBS Switzerland is jointly and severally responsible for all obligations, including payment obligations, on the Outstanding Securities. This co-obligor structure is substantively equivalent to a “full and unconditional” guarantee by UBS Switzerland.2 It is clear from the Notes to paragraphs
(b), (c) and (e) of Rule 3-10 that a joint and several co-obligation between a parent and a subsidiary is equivalent for these purposes to a full and unconditional
guarantee by the subsidiary of the parent’s obligations. Thus, this co-obligation structure fits the second prong of clause (iv) of General Instruction I.A.5. to Form
F-3.

1
 The relevant indentures provide in pertinent part that UBS Switzerland “fully, unconditionally and
irrevocably assumes and agrees to pay, perform and discharge, jointly and severally with the Company, the due and punctual payment” of all amounts payable under the Outstanding Securities.

2
 Pursuant to Rule 3-10 of Regulation
S-X a guarantee is “full and unconditional” if, when the issuer fails to make a scheduled payment, the guarantor is obligated to make the scheduled payment immediately and, if it doesn’t, any
holder of the guaranteed security may immediately bring suit directly against the guarantor for payment of all amounts due and payable.

 Ms. Era Anagnosti

 Securities and Exchange
Commission

Page 3

 We have
been advised by UBS Switzerland that it does not have any warrants outstanding that are convertible into other securities and thus all of the securities being registered by UBS Switzerland for market-making purposes are non-convertible securities. As described above, UBS Switzerland securities have only been registered for market-making purposes and it is not registering any securities to be issued in the future. Accordingly, all
of the registered UBS Switzerland securities are “non-convertible securities, other than common equity.”

For the reasons described above, UBS respectfully submits that UBS Switzerland is eligible to register its outstanding securities for
market-making purposes on Form F-3 pursuant to clause (iv) of General Instruction I.A.5.

*    *    *    *    *

 Ms. Era Anagnosti

 Securities and Exchange
Commission

Page 4

 If you
have additional questions or require any additional information with respect to the Registration Statement or this letter, please do not hesitate to contact me at (212) 558-4175 or by email
(clarkinc@sullcrom.com), or Steven J. Borenstein at (212) 558-3055 or by email (borensteins@sullcrom.com).

 Yours truly,

 /s/ Catherine M. Clarkin

 Catherine M. Clarkin

cc:

 David Lin

 (Securities and Exchange
Commission)

 David Kelly

 Timothy Geller

(UBS AG)

 Rebecca J. Simmons

 Steven J. Borenstein

(Sullivan & Cromwell LLP)

Mail Stop 4720

February 2, 2017

Via E-mail
Kirt Gardner
Chief Financial Officer
UBS AG
677 Washington Boulevard
Stamford, Connecticut 06901

Re: UBS Group AG
 UBS AG
 Form 20-F for Fiscal Year Ended December 31, 2015
Filed March 18, 2016
File No s. 1-36764 and 1-15060

Dear Mr. Gardner :

We have completed our review of your filing s.  We remind you that the company and its
management are responsible for the accuracy and adequacy of  their disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Kevin W. Vaughn

Kevin W. Vaughn
Accounting Branch Chief
Office of Financial Services

CORRESP
1
filename1.htm

correspondence

  AB

  UBS AG

  Postfach

  8098 Zürich

  Tel. +41-44-234 11 11

  Corporate Center

  Group CFO Management

  Kirt Gardner

  Tel. +41-44-237-3791

  kirt.gardner@ubs.com

  www.ubs.com

October
14, 2016

Mr.
Christian N. Windsor

Special
Counsel

Office
of Financial Services

Securities
and Exchange Commission

100
F Street, NE

Washington
DC 20549-1090

Re:
      UBS Group AG

UBS
AG

Form
20-F for Fiscal Year Ended December 31, 2015

Filed
March 18, 2016

Form
6-K dated July 29, 2016

File
Nos. 1-36764 and 1-15060

UBS AG
HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN ACCORDANCE
WITH 17 C.F.R. §200.83

Dear Mr.
Windsor:

We
respectfully submit a response to your letter dated September 29, 2016 from the
staff of the Securities and Exchange Commission relating to Form 20-F for the
Fiscal Year Ended December 31, 2015, filed March 18, 2016, and Form 6-K dated
July 29, 2016.

1.    "In
your letter to us dated September 30, 2013, you described contacts with Syria
and Sudan. As you are aware, Syria and Sudan are designated by the U.S.
Department of State as state sponsors of terrorism and are subject to U.S.
economic sanctions and export controls. Your Form 20-F does not include
information about those countries. Please describe to us the nature and extent
of your past, current, and anticipated contacts with Syria and Sudan since your
2013 letter, whether through subsidiaries, affiliates, customers or other
direct or indirect arrangements. You should describe any products, services, or
technology you have provided to Syria and Sudan, directly or indirectly, and
any agreements, commercial arrangements, or other contacts with the governments
of those countries or entities they control."

***
CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

  AB

  CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

  UBS
  Group AG

  UBS AG

  Form
  20-F for Fiscal Year Ended December 31, 2015

  Filed
  March 18, 2016

  Form 6-K
  dated July 29, 2016

  File
  Nos. 1-36764 and 1-15060

  Page 2 of 6

2.    "Please
discuss the materiality of any contacts with Syria and Sudan you describe in
response to the comment above, and whether those contacts constitute a material
investment risk for your security holders. You should address materiality in
quantitative terms, including the approximate dollar amounts of any associated
revenues, assets, and liabilities for the last three fiscal years and the
subsequent interim period. Also, address materiality in terms of qualitative
factors that a reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities upon a
company’s reputation and share value. As you know, various state and municipal
governments, universities, and other investors have proposed or adopted
divestment or similar initiatives regarding investment in companies that do
business with U.S.-designated state sponsors of terrorism. You should address
the potential impact of the investor sentiment evidenced by such actions
directed toward companies that have operations associated with Syria and
Sudan."

***
CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

  AB

  CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

  UBS
  Group AG

  UBS AG

  Form
  20-F for Fiscal Year Ended December 31, 2015

  Filed
  March 18, 2016

  Form 6-K
  dated July 29, 2016

  File
  Nos. 1-36764 and 1-15060

  Page 3 of 6

3.    "Please
address the following regarding your disclosure that you have changed your
definition of cash and cash equivalents to exclude cash collateral receivables
on derivative instruments with bank counterparties".

3.1  "Please
describe the drivers for this change in classification. As part of your
response, tell us how you considered paragraph 7 of IAS 7 in determining your
treatment of these receivables before and after the change."

IAS 7,
paragraph 6, defines cash equivalents as short-term, highly liquid investments
that are readily convertible to known amounts of cash and which are subject to
an insignificant risk of change in value. IAS 7 also refers to activities that
form an integral part of an "entity's cash management" and are
included as a component of cash and cash equivalents, as they are held for the
purpose of meeting ‘’short term cash commitments rather than for investment or
other purposes"(IAS 7 paragraph 7).

Prior
to applying the change, UBS had taken the view that cash collateral receivables
on derivatives with bank counterparties meet the definition of cash equivalents
as (i) the cash receivable represents cash delivered to satisfy short term cash
commitments arising from derivative trading activity; and (ii) a significant
portion of the Group's over-the-counter, or OTC, derivative agreements
permitted either party to post either cash or eligible securities to meet
margin requirements.

Further,
since January 2015, UBS is subject to the Liquidity Coverage Ratio
("LCR") requirements of the Basel III framework, as adopted by
Switzerland and its banking regulator FINMA, on a consolidated basis as well as
for its Swiss Systemically Relevant Banks, UBS AG and UBS Switzerland AG, each
on a standalone basis. Please refer to page 235 in our Annual Report 2015. The
objective of the LCR is to promote the short-term resilience of the liquidity
risk profile of banks by ensuring that banks have an adequate stock of
unencumbered high-quality liquid assets, or HQLA, which can be easily converted
in private markets to cash in order to meet their liquidity needs for a 30
calendar day liquidity stress scenario.  We have reviewed the determination of
cash equivalents in light of (i) the Basel III LCR framework, which does not
include cash collateral on derivative instruments in the definition of HQLA;
and (ii) the change in standard terms of new collateral agreements for OTC
derivatives that generally no longer permit cash collateral to be replaced by
securities collateral, and, based on such review, voluntarily refined our
definition of cash equivalents accordingly. This in our view enhances the
relevance and consistency of information provided in the statement of cash
flows.

This
change in our statement of cash flows had no impact on other primary financial
statements or any other Group regulatory measure, including Capital, Capital
ratios, Leverage Ratio and Liquidity Coverage Ratio.

3.2  "Tell
us the duration terms of the derivative contracts which are collateralized by
the cash receivables formerly treated as cash equivalents."

The cash
collateral receivables on derivative instruments with banks represent cash that
has been transferred under an ISDA Credit Support Annex ("CSA") to
margin bilateral OTC derivatives. The individual derivatives have varying
contractual maturities as detailed below.  The credit risk associated with
these contracts is managed on a daily basis by counterparty across the various
derivative products, maturities and currencies subject to the same CSA
agreement. UBS

  AB

  CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

  UBS
  Group AG

  UBS AG

  Form
  20-F for Fiscal Year Ended December 31, 2015

  Filed
  March 18, 2016

  Form 6-K
  dated July 29, 2016

  File
  Nos. 1-36764 and 1-15060

  Page 4 of 6

treats
and discloses these derivatives as "on demand" instruments. Please
refer to our Annual Report 2015 Note 27b Maturity analysis of financial
liabilities.

The
contractual maturities of derivative instruments with bank counterparties as of
31 December 2015 were as follows: Positive Replacement Values: 21% up to 3
months; 15% 3-12 months; 31% 1-5 years; and 33% over 5 years. For Negative
Replacement Values: 22% up to 3 months; 16% 3-12 months; 32% 1-5 years; and 31%
over 5 years.

3.3  "Clarify
whether all cash collateral receivables from banks for your derivative
contracts were formerly included in cash equivalents or only a subset of your
cash collateral receivables meeting certain parameters. Please identify any
such parameters in your response."

We
can confirm that all cash collateral receivables on derivative instruments with
bank counterparties were formerly included in cash equivalents. Please refer to
our Annual Report 2014 statement of cash flows (footnote 2 page 404) and Note
11 for a breakdown of our cash collateral receivables on derivative instruments
(page 440).

4.    "We
note your disclosure that effective June 30, 2016 you elected to convert your interest
rate swaps transacted with the London Clearing House ("LCH") from the
previous collateral model to a settlement model. Your disclosure goes on to
state that the interest rate swaps are now legally settled on a daily basis
resulting in the derecognition of the associated assets and liabilities, and
the effect of this change as of June 30, 2016 is a CHF 93 billion reduction in
gross cash collateral receivables and payables on derivative instruments and
corresponding netting presented in Note 12. Please address the following:

4.1  "Tell
us in more detail the specific terms that changed as a result of the conversion
that resulted in the interest rate swaps now being considered legally settled
on a daily basis. As part of your response, please tell us whether the timing
or amount of cash flows related to the interest rate swaps has changed."

LCH made
significant amendments to its rules that became effective on December 17, 2015.
These amendments were approved by the Bank of England and Commodity Futures Trading
Commission and have resulted in two models for interest rate swaps cleared
through LCH for clearing members' house accounts. The traditional
collateral-to-market ("CTM") model has been supplemented by a
settlement-to-market (“STM”) model. The difference between the two models is a
legal re-characterization of the variation margin. This legal
re-characterization under the STM model was based on amendments that redefined
the nature of the variation margin from a contractual payment of collateral to
a contractual settlement payment. Under the CTM model, variation margin is
legally considered to be collateral related to the derivative instrument, while
under the STM model, variation margin legally settles the net present value of
the derivative instrument on a daily basis without terminating or extinguishing
the contract. The conversion from CTM to STM has no impact on the timing or
amount of cash flows or risks inherent in the contract. Under the revised
rules, clearing members can choose, but are under no obligation, to convert all
trades within their house accounts from the CTM model to the STM model with
clearing members being required to provide LCH with 5 workings days' notice of
their intention to convert. UBS provided the required notification to allow it
to convert on 30

  AB

  CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

  UBS
  Group AG

  UBS AG

  Form
  20-F for Fiscal Year Ended December 31, 2015

  Filed
  March 18, 2016

  Form 6-K
  dated July 29, 2016

  File
  Nos. 1-36764 and 1-15060

  Page 5 of 6

June
2016. This change had no impact on UBS’s net balance sheet position as UBS
applies IAS 32 netting principles in order to net the gross derivative balances
against cash collateral payables / receivables on derivative instruments for
balance sheet presentation purposes.

Given
that under the STM construct, payment or receipt of variation margin represents
legal settlement of the derivative instrument, we consider the legal
re-characterization of the variation margin to be dispositive from an
accounting perspective.  Specifically, given the legal conclusion that payments
of variation margin under an STM model do not give rise to additional payables
or receivables between the payer or payee, and are instead a legal settlement
of amounts due under the contractual terms of the derivative instruments, it
would not be appropriate to reflect variation margin amounts as separate units
of account (cash collateral payables / receivables on derivative instruments)
arising from said instruments. Consequently, it was concluded that under the
STM model the derivative instrument is the relevant unit of account. Such
derivative instrument also includes any price alignment interest that is paid
to eliminate a basis difference in the pricing of central clearing counterparty
cleared contracts as compared to collateralized bilateral OTC contracts.

4.2  "Tell
us whether any of the interest rate swaps that were affected by the conversion
were included in hedge accounting relationships at the time of conversion. If
so, please tell us your consideration of the guidance in paragraphs 91 and 101
of IAS 39."

The above
changes affected interest rate swaps that are included in all categories of
UBS's designated hedge accounting relationships except for its net investment
hedges. In light of various factors, we de- and re-designated all affected
hedge accounting relationships at the point of conversion based on IAS 39.91c)
and IAS 39.101d), which allow for a voluntary revocation of hedge accounting
relationships. No additional disclosures were provided given there is no
requirement under IFRS 7 to disclose a de- and re-designation of a hedge
accounting relationship.  In addition, the change had no material impact on the
nature of our designated hedges, the items included within those hedges, the
hedge effectiveness testing methodologies used or the results of those tests.

  AB

  CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

  UBS
  Group AG

  UBS AG

  Form
  20-F for Fiscal Year Ended December 31, 2015

  Filed
  March 18, 2016

  Form 6-K
  dated July 29, 2016

  File
  Nos. 1-36764 and 1-15060

  Page 6 of 6

We
appreciate the opportunity to provide you with this additional information. If
you wish to discuss any of our responses or require further information, please
do not hesitate to contact Todd Tuckner at +1 203-719-0381
(todd.tuckner@ubs.com).

Very
truly yours,

UBS
AG

/s/
Kirt Gardner                                                  /s/ Todd Tuckner

Kirt Gardner                                                    Todd
Tuckner

Group Chief Financial
Officer                           Group Controller and Chief Accounting Officer

Mail Stop 4720

September 29, 2016

Via E-mail
Kirt Gardner
Chief Financial Officer
UBS Group  AG
677 Washington Boulevard
Stamford, Connecticut 06901

Re: UBS Group AG
 UBS AG
 Form s 20-F for Fiscal Year Ended December 31, 2015
Filed March 18, 2016
Form 6 -K dated July 29, 2016
File No s. 1-36764 and 1-15060

Dear Mr. Gardner :

We have reviewed your filing s and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe  our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Form 20 -F

Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syrian Human Rights Act,
page 12

1. In your letter to us dated September 30, 2013, you described contacts with Syria and
Sudan.  As you are aware, Syria and Sudan are designated by the U.S. Department of
State as state sponsors of terrorism and  are subject to U.S. economic sanctions and export
controls.  Your Form 20 -F does not include information about those countries.  Please
describe to us the nature and extent of your past, current, and anticipated contacts with
Syria and Sudan since your 20 13 letter, whether through subsidiaries, affiliates,
customers or other direct or indirect arrangements.  You should describe any products,
services, or technology you have provided to Syria and Sudan, directly or indirectly, and

Kirt Gardner
UBS Group  AG
September 29, 2016
Page 2

 any agreements, commercial  arrangements, or other contacts with the governments of
those countries or entities they control.

2. Please discuss the materiality of any contacts with Syria and Sudan you describe in
response to the comment above, and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent inter im period.  Also, address
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.  As you know, various state and
municipal governments, universities, and other investors have proposed or adopted
divestment or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism.  You should  address the potential impact of
the investor sentiment evidenced by such actions directed toward companies that have
operations associated with Syria and Sudan.

Consolidated Financial Statements of UBS Group AG, page 390

Note  1 Summary of significant ac counting policies , page 409

b) Changes in accounting policies, comparability and other adjustments , page 428

Statement of cash flows – definition of cash and cash equivalents , page 428

3. Please address the following regarding your disclosure that you have  changed your
definition of cash and cash equivalents to ex clude cash collateral receivables on
derivative instruments with bank counterparties.

 Please describe the drivers for this change in classification.  As part of your response, t ell
us how you co nsidered paragraph 7 of IAS 7 in determining your treatment of these
receivables before and after the change.

 Tell us the duration terms of the derivative contracts which are collateralized by the cash
receivables formerly treated as cash equivalents.

 Clarify whether all cash collateral receivables from banks for your derivative contracts
were formerly included in cash equivalents or only a subset of your cash collateral
receivab les meeting certain parameters.  Please identify  any suc h parameters in y our
response.

Kirt Gardner
UBS Group  AG
September 29, 2016
Page 3

Form 6 -K filed on July 29, 2016

UBS Group AG Interim Consolidated Financial Statements , page 75

Note 1. Basis of Accounting, page 86

London Clearing House interest rate swaps converted to a settlement model, p age 86

4. We note your disclosure that effective June 30, 2016 you elected to convert your interest
rate swaps transacted with the London Clearing House (LCH) from the previous
collateral model to a settlement model.   Your disclosure goes on to state that the intere st
rate swaps are now legally settled on a daily basis resulting in the derecognition of the
associated assets and liabilities, and the effect of this change as of June 30, 2016 is a CHF
93 billion reduction in gross cash collateral receivables and payable s on derivative
instruments and corresponding netting presented in Note 12.   Please address the
following:

 Tell us in more detail the specific terms that changed as a result of the conversion that
resulted in the interest rate swaps now being considered l egally settled on a daily
basis.   As part of your response, please tell us whether the timing or amount of cash flows
related to the interest rate swaps has changed.

 Tell us whether any of the interest rate swaps that were affected by the conversion were
included in hedge accounting relationships at the time of conversion.   If so, please tell us
your consideration of the guidance in paragraphs 91 and 101 of IAS 39.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, th ey are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceedin g initiated by
the Commission or any person under the federal securities laws of the United States.

Kirt Gardner
UBS Group  AG
September 29, 2016
Page 4

You may contact  Michael Henderson, Staff Accountant at (202) 551 -3364 or Kevin W.
Vaughn, Branch Chief at (202) 551 -3494  if you have questions regarding comments on the
financial statements and related matters.  Please contact me at (202) 551 -3419 with any other
questions.

Sincerely,

 /s/ Christian N. Windsor

Christian N. Windsor
Special Counsel
Office of Financial Services

August 6, 2014

Via E -mail
Tom Naratil
Chief Financial Officer
UBS AG
677 Washington Boulevard
Stamford, Connecticut 06901

Re:  UBS AG
Form 20 -F for Fiscal Year Ended December 31, 2013
Filed March 14, 2014
File No. 1 -15060

Dear Mr. Naratil:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing  and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for  the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Suzanne Hayes
Suzanne Hayes
Assistant Director

CORRESP
1
filename1.htm

CORRESP

 Via EDGAR

Ms. Amy L. Starr

 Chief, Office of Capital Markets
Trends

 Division of Corporation Finance

 United States
Securities and Exchange Commission

 100 F Street, N.E.

Washington, DC 20549

 March 5, 2014

Re:
UBS AG

424 Prospectuses relating to Registration Statement on Form F-3ASR

Filed January 11, 2012

File No. 333-178960

 Dear Ms. Starr:

We respectfully submit the responses set forth below to the comment letter, dated February 11, 2014 (the “Comment Letter”), from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding 424 Prospectuses relating to issuances of exchange traded notes (“ETNs”) pursuant to UBS AG’s Registration Statement on Form F-3ASR
filed January 11, 2012 (File No. 333-178960) (the “Registration Statement”). We appreciate your extension of the response deadline to March 5, 2014. For your convenience, we have included the Staff’s comments below,
followed by our responses. Please note that references to “UBS”, “we”, “our” or “us” in our responses refer to UBS AG.

Terms of Offering

 1. We have
observed that frequently the prospectus supplement does not clearly describe the terms of the ETN being offered. As a result, investors may have difficulty understanding what they are purchasing and how the ETN operates. For example, some prospectus
supplements use highly complex defined terms without explaining those terms in the context of the ETN, while others do not clearly describe the precise mechanics of the ETN, including payment at maturity or redemption. Please revise your prospectus
supplements, as appropriate, to disclose the material terms of each ETN in a clear, concise and understandable manner. Refer to Rule 421(b) of the Securities Act of 1933.

Response:

 We believe our offering documentation
discloses the material terms of each ETN in a clear, concise and understandable manner. We issue our Exchange Traded Access Securities (“ETRACS”) ETNs pursuant to individual prospectus supplements to the base prospectus, dated
January 11, 2012 (the “Base Prospectus”), or, in the case of our “Monthly Pay 2xLeveraged ETRACS”, a product supplement, dated August 5, 2013, to the Base Prospectus, as supplemented by pricing supplements that contain
the specific terms of each ETN being offered.1 We have structured our ETN Offering Documents in this manner to clearly identify the risk profile associated with each ETN structure and strategy as
well as the risks associated with the underlying asset class.

 -1-

 In our ETN Offering Documents, we disclose the material terms of each ETN (i) on the cover page of the
applicable prospectus supplement (or pricing supplement, as applicable), (ii) in summary narrative form in the “Prospectus Summary”, which is intended to provide an overview of the nature of the ETN, its risk profile, the underlying
asset class, payment and fee mechanics and redemption and call provisions, and (iii) in the “Specific Terms of the Securities” section, which provides a comprehensive discussion of the key terms of the ETN.

Moreover, the offering documents also provide hypothetical examples to illustrate how a hypothetical series of ETNs would perform under hypothetical
circumstances. These examples demonstrate how payments would be calculated at maturity and upon redemption, giving effect to the applicable fees. We believe that these examples, together with the summary and comprehensive disclosure of the specific
terms of the ETNs, present the terms of the ETNs to investors in a clear and concise manner and provide investors with the information they need to understand what they are purchasing and how the ETNs operate.

We acknowledge the complexity of ETN descriptions and we will consider our disclosure in the future in light of the Staff’s comment.

2. Please revise your prospectus supplements, as appropriate, to disclose whether the ETN issuer may cease or suspend and restart sales of
the notes at any time at the issuer’s discretion. Also, describe the potential impact these actions may have on the market price and liquidity of the ETNs in the secondary market. Tell us whether you consider the issuer’s discretion to
suspend and restart sales to be a material risk to investors in the offering and, if so, please provide appropriate risk factor disclosure in future filings.

Response:

 Our ETN Offering Documents disclose
that UBS may suspend or cease sales of the ETNs at any time, at its discretion. This disclosure appears in the sections entitled “Prospectus Supplement Summary — Selected Risk Considerations” and “Supplemental Plan of
Distribution”. Our ETN Offering Documents also provide risk disclosure regarding the potential impact such suspensions could have on the market for the ETNs. For example, one risk factor states that UBS may suspend or cease sales of the
relevant ETN at any time, potentially causing the liquidity of the market for the ETN to vary materially. In addition, another risk factor states that “supply and demand for the Securities, including to the extent affected by inventory
positions with UBS or any market maker” is a factor affecting the securities’ market value. We believe that the disclosure described above is sufficient to inform investors that UBS may cease or suspend sales of the securities and the
possible consequences of such a decision.

1
In this response letter, we refer to the Base Prospectus as supplemented by (1) a prospectus supplement or (2) a product supplement and related pricing supplement and, in each case, any related free writing prospectus,
as applicable, as the “ETN Offering Documents”.

 -2-

 Indicative Value

3. We note that some prospectus supplements for ETN offerings state that the “indicative value” of the ETN will be published on a
regular basis, such as daily, including through third parties. Please explain to us the purpose of calculating indicative value and why it is relevant to investors. Further, tell us whether and where the ETN’s indicative value is publicly
available to any investor without charge and how often it is updated.

 Response:

The intraday indicative value is meant to approximate the intrinsic economic value of the ETN. It is generally provided for reference purposes only, and is not
intended as a price, quotation or economic term of the ETN. Its calculation permits investors to compare the secondary market prices of the ETN to the intrinsic value of the ETN based on the level of the underlying index and the accrued fees at that
time, which may inform their investment decision to purchase, sell or exercise the redemption right. In addition, for certain ETNs, UBS has the right to accelerate the maturity date if the indicative value reaches a specified minimum value. Finally,
calculation and publication of the indicative value is a requirement to list the ETN on NYSE Arca under NYSE Arca Equities Rule 5.2(j)(6).

 The indicative
value is published and disseminated every 15 seconds during normal trading hours and is publicly available without charge on Yahoo! Finance by typing “^[ETN Ticker Symbol]-IV” into the search bar and on Bloomberg by typing “[ETN
Ticker Symbol]IV <EQUITY> <GO>” into the search bar. It is also available on the UBS ETRACS public website for each ETN on a twenty minute delayed basis. In the future, we intend to disclose more prominently in the ETN Offering
Documents the availability and source of this information.

 4. We note that some prospectus supplements for ETN offerings include
numeric formulas describing how the indicative value of an ETN is calculated without providing sufficient narrative explanation as to how the formula works, and therefore how the security’s terms work. Please provide narrative disclosure that
describes the inputs and mechanics of such formulas in a clear, concise and understandable manner so that investors may evaluate how the terms of the security work and are calculated.

Response:

 UBS strives to provide investors with
clear, concise and understandable explanations of each ETN, including narrative explanations of numeric formulas. We will review our narrative explanations and other disclosure in light of the Staff’s comment to determine whether additional
disclosure is appropriate.

 5. If you include information about indicative value in your prospectus supplements, please also disclose
the relationship among the indicative value, the market value of the ETN relative to the initial offering price to the public, and the redemption amount. Please also provide a risk factor discussing the risk that ETNs may trade at a substantial
premium or discount in relation to the value of the ETN determined or disclosed by the issuer (whether as “indicative value” or otherwise) or the redemption amount of the ETN.

 -3-

 Response:

UBS discloses information regarding the relationship among the indicative value, the market value, and the redemption amount of each ETN. For example, under
the section “Valuation of the Securities” in the ETN Offering Documents, UBS explains that indicative value is meant to approximate the intrinsic economic value of the ETN, although the actual trading prices of the ETNs may vary
significantly from their indicative value. In addition, UBS discloses that the redemption provision is meant to induce arbitrageurs to counteract any trading of the ETN at a premium or discount to its indicative value. The offering documents also
include risk disclosure regarding fluctuations in secondary market prices, including a risk factor stating that the market value of the securities in the secondary market could be discounted from the issue price, potentially leading to significant
losses.

 Redemption Value

 6. We
have observed that in most ETN offerings, the holder may submit the notes for redemption at a “redemption value.” However, the prospectus or prospectus supplement may not clearly disclose the method of determining the redemption value (or
amount) for the ETN or indicate whether the redemption value is publicly available prior to an investor’s redemption. Please revise, as applicable, to disclose this information.

Response:

 UBS discloses in the ETN Offering
Documents the method for determining the redemption amount for its ETNs. The disclosure is prominently made on the cover of the applicable prospectus or pricing supplement, and in greater detail under “Specific Terms of the Securities”.

 The redemption amount is determined according to a formula set forth in the applicable prospectus or pricing supplement, which uses a closing valuation
of the underlying index as of a specified date or period of time after the redemption notice has been delivered. Accordingly, at the time investors elect to redeem their securities, they will not know the amount payable upon redemption. UBS
discloses this fact in its risk factors, and warns that investors will be exposed to market risk in the event the market fluctuates after confirmation of their redemption request but prior to the relevant redemption date. The risk factor also
indicates that the redemption amount will be reduced by any applicable fees.

 Fees

7. Please revise your disclosure to clearly describe all fees that may be charged relating to the ETNs, including but not limited to, as
applicable, annual fees, redemption fees, event risk hedge costs, futures execution costs, and index calculation fees. Identify the party responsible for payment of each fee, and describe how, if applicable, such fees may change based on the
performance of any referenced index or asset. In addition, please explain when fees are collected and what effect the fees have on the redemption amount and the indicative value of the ETN.

 -4-

 Response:

UBS prominently discloses the fees that investors will bear in connection with the purchase of the ETNs on the cover page of each prospectus or pricing
supplement and, importantly, the fact that the fees will reduce any payment amount received by investors. The fees and related risks are described in greater detail in the narrative descriptions of the payment amounts at maturity, upon redemption,
upon a call by the issuer or upon an acceleration, as applicable, as well as under “Risk Factors”. For example, the ETN Offering Documents disclose that we charge two principal fees, the accrued fees and the redemption fee, and the manner
in which they will be calculated (e.g., accrue daily based on a fixed percentage in relation to the value of the ETN or the performance of the referenced index). We believe our disclosure provides investors with a clear statement of the fees that
will be charged by UBS in relation to its ETNs.

 Conflicts of Interest

8. We note that prospectus supplements for ETN offerings typically include disclosure about activities of the issuer and its affiliates
that may create conflicts of interest, such as trading activities, hedging, and publishing research reports. To the extent you or your affiliates engage in activities that create material conflicts of interest, please revise to disclose those
activities and the types of conflicts they create. Also describe the potential impact of such activities and conflicts on the supply, pricing and market for the ETN.

Response:

 The ETN Offering Documents currently
include disclosure regarding conflicts of interest created by activities of UBS and its affiliates. For example, UBS includes several risk factors that discuss its activities and those of its affiliates and the effects those activities may have on
the market for the ETNs. These risk factors discuss (1) the hedging activities that UBS and its affiliates may engage in involving the underlying index constituents, futures, options, exchange-traded funds or other derivative products on such
index constituents or the underlying index itself, (2) how UBS and its affiliates expect to engage in trading activities related to the underlying index and the index constituents that may present a conflict between investors’ interests in
the ETNs and the interests of UBS and its affiliates in their proprietary accounts, in facilitating transactions for their customers and in accounts under their management and (3) the fact that UBS and its affiliates may publish research,
express opinions or provide recommendations that are inconsistent with investing in the ETNs. The risk factors warn that each of these activities could have an adverse impact on the level of the underlying index or the market value of the ETNs.

UBS also describes the conflicts of interest that exist within the meaning of the Financial Industry Regulatory Authority, Inc. (“FINRA”) Rule 5121
in relation to its affiliates, UBS Securities LLC and UBS Financial Services Inc., in both the “Prospectus Supplement Summary” and “Supplemental Plan of Distribution” sections of the applicable prospectus or pricing supplement.

 -5-

 Finally, UBS describes how it may use the proceeds from sales of the ETNs to enter into hedging transactions,
which could affect the market value of the securities.

 We believe that this disclosure is sufficient to inform investors of the risks resulting from the
activities of UBS and its affiliates, which may create conflicts of interest, and of the impact of such activities on the pricing and market for the ETNs.

Outstanding ETNs

 9. We note that
issuers of ETNs may provide public information about the number and dollar amount of outstanding ETNs in a series. Please disclose where the number and amount of outstanding ETNs in a series is available to investors at any point in time.

 Response:

 UBS provides public
information on the current market capitalization and the number of outstanding ETNs on its website, http://etracs.ubs.com/, on the product page for each specific ETN. For example, information regarding the ETRACS Alerian MLP Index ETN is available
at http://etracs.ubs.com/product/detail/index/ussymbol/AMU, by clicking the “Performance” tab. In addition, t

February 11, 2014
 Via E-mail
Sarah M. Starkweather, Esq. Executive Director UBS AG 677 Washington Boulevard Stamford, CT  06901
Re: UBS AG
  424 Prospectuses relating to Registration Statement on Form F-3ASR
Filed January 11, 2012
  File No. 333-178960

Dear Ms. Starkweather:
 We are writing this letter in connection with our selective review of takedowns of
exchange- traded notes (“ETNs”) from sh elf registration statements.  In this letter, we identify
areas where we believe there could be disclosure improvements that would benefit investors.  We are issuing the following comments in an effort to enhance disclosures in your future ETN offerings.

This letter reflects observations from our se lective review of prospectus supplements for
ETN offerings by a number of different financial institutions.  Although we reviewed certain
takedowns from your existing shelf registration statement, we are including comments that may
or may not specifically apply to disclosures with respect to all of your ETN offerings.  If you disagree with a comment or think it does not apply to your ETN program, please explain why in your response letter.
 This letter may not address all of the disclosure issues that could arise in your ETN
offerings.  It is intended only to highlight the issues described in the comments below.  We recommend that you also review our April 2012 samp le comment letter to issuers of structured
notes for additional disclosure matters that may be applicable to ETN offerings.
1

Terms of Offering
 1. We have observed that frequently the prospect us supplement does not clearly describe the
terms of the ETN being offered.  As a result, investors may have difficulty understanding
what they are purchasing and how the ETN operates.  For example, some prospectus supplements use highly complex defined terms without explaining those terms in the

1  The comment letter to issuers of structured notes is available on our website at
http://sec.gov/divisions/corpfin/ guidance/structurednote0412.htm .

Sarah M. Starkweather UBS AG February 11, 2014 Page 2

 context of the ETN, while others do not clearly describe the precise mechanics of the
ETN, including payment at maturity or redemption.  Please revise your prospectus supplements, as appropriate, to disclose th e material terms of each ETN in a clear,
concise and understandable ma nner.  Refer to Rule 421(b) of the Securities Act of 1933.

2. Please revise your prospectus supplements, as appropriate, to disclose whether the ETN
issuer may cease or suspend and restart sales of the notes at any time at the issuer’s discretion.  Also, describe the potential impact these actions may have on the market price and liquidity of the ETNs in the seconda ry market.  Tell us whether you consider
the issuer’s discretion to suspend and restart sa les to be a material risk to investors in the
offering and, if so, please provide appropriate risk factor disclosure in future filings.

Indicative Value

3. We note that some prospectus supplements for ETN offerings state that the “indicative
value” of the ETN will be published on a regular basi s, such as daily, including through
third parties.  Please explain to us the purpose of calculating indicati ve value and why it
is relevant to investors.  Further, tell us whether and where the ETN’s indicative value is
publicly available to any investor without charge and how often it is updated.
 4. We note that some prospectus supplements for ETN offerings include numeric formulas
describing how the indicative value of an ETN is calculated without providing sufficient
narrative explanation as to how the formula works, and therefore how the security’s terms
work.  Please provide narrative disclosure th at describes the inputs and mechanics of such
formulas in a clear, concise and understandable manner so that investors may evaluate
how the terms of the security work and are calculated.
5. If you include information about indicative value in your prospectus supplements, please
also disclose the relationship among the indicative value, the market value of the ETN relative to the initial offering price to the public, and the redemption amount.  Please also provide a risk factor discussing the risk that ETNs may trade at a substantial premium or discount in relation to the value of the ETN determined or disclosed by the issuer (whether as “indicative value” or otherwise) or the redemption amount  of the ETN.
 Redemption Value

6. We have observed that in most ETN offerings, the holder may submit the notes for
redemption at a “redemption value.”  However, the prospectus or prospectus supplement may not clearly disclose the method of determining the redemption value (or amount) for the ETN or indicate whether the redemption value is publicly available prior to an investor’s redemption.  Please revise, as applicable, to disclose this information.

Sarah M. Starkweather UBS AG February 11, 2014 Page 3

 Fees

7. Please revise your disclosure to clearly de scribe all fees that may be charged relating to
the ETNs, including but not limited to, as applicable, annual fees, redemption fees, event risk hedge costs, futures execution costs, and index calculation fees.  Identify the party responsible for payment of each fee, and describe how, if applicable, such fees may change based on the performance of any referenced index or asset.  In addition, please explain when fees are collected and what effect the fees have on the redemption amount and the indicative value of the ETN.
Conflicts of Interest
 8. We note that prospectus supplements for ETN offerings typically include disclosure
about activities of the issuer and its affiliates that may create conflicts of interest, such as
trading activities, hedging, and publishing research reports.  To the extent you or your affiliates engage in activities that create material conflicts of interest, please revise to disclose those activities and the types of conflicts they create.  Also describe the potential impact of such activities and conflicts on the supply, pricing and market for the ETN.
 Outstanding ETNs
 9. We note that issuers of ETNs may provide public information about the number and
dollar amount of outstanding ETNs in a series.  Please disclose where the number and
amount of outstanding ETNs in a series is available to investors at any point in time.

Plan of Distribution
 10. Please provide a detailed explanation of your methods of sale for ETNs, including the
involvement of broker-dealers as initial purchasers of ETNs from the issuer, whether such broker-dealers are identified as underw riters in the prospectus supplement and how
such broker-dealers satisfy prospectus delivery  obligations under the S ecurities Act.  See
Item 508 of Regulation S-K.
 Disclosure Format

11. We note that some prospectus supplements include disclosure for numerous ETN
offerings with different investment profiles.  Considering that different ETNs may have
different features and risks for investors to evaluate, please explain to us why you believe that providing disclosure for multiple ETN offerings in a single prospectus supplement is appropriate.

Sarah M. Starkweather UBS AG February 11, 2014 Page 4

 Security Titles

12. Please evaluate the titles used for your ETNs and avoid titles that may suggest investors
are purchasing equities or other types of securities instead of an unsecured debt
obligation.  For example, titles incorporati ng the term “shares” may suggest that in vestors
are purchasing an equity security, rather than a debt instrument.  In addition, please avoid titles that may suggest you are offering interests in an exchange traded fund registered under the Investment Company Act of 1940.
 Short Sales

13. We note that in some offerings there is disclosure in the prospectus supplement stating
that broker-dealers and other persons may make short sales of ETNs and may cover such
short positions by borrowing ETNs from the issuer or its affiliates.  In some cases the issuer has agreed to repurchase those ETNs.  These activities may impact in the short or long term the number of ETNs outstanding at any point.  Please disclose whether you intend to engage in such activities and if so how you will publicly disclose such loans and repurchases.  Please confirm you will register  these transactions under the Securities Act
of 1933.  If applicable, please provide risk factor disclosure that describes the market impact of short sales and the effect that securities lending may have on the number of ETNs outstanding at any time.
 Regulation M

14. We have observed that a large divergence between the ETN’s market value and the value
of the reference index of the ETN can emerge  (for example, where ETN issuers suspend
further issuances or otherwise limit the availability of newly issued ETNs).  Please explain how your redemptions in such circ umstances comply with the requirements of
Rule 102 of Regulation M.  If these redemptions are done in reliance on no-action letters granting relief from Rule 102 and permitting issuers to redeem an ETN during the ETN’s
distribution
2, please explain how the representation that the market value of the ETN not
vary substantially from the value of th e underlying or reference index is met.

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 facts and circum stances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may have
additional comments.
 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filings to be certain that the filings include the information the Securities Act and all applicable Securities Act rules require.  Since the company and its management are in possession

2  See e.g. Barclays Bank PLC, Staff No-Action letter (J uly 27, 2006) or Deutsche Bank AG, Staff No-Action
Letter (October 12, 2007).

Sarah M. Starkweather UBS AG February 11, 2014 Page 5

 of all facts relating to a company’s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

x the company is responsible for the adequacy and accuracy of the disclosure in the
filings;

x staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

x the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
 You may contact David Walz at (202) 551-3358 or me at (202) 551-3860 with any
questions regarding these comments.
  Sincerely,  /s/ Amy M. Starr

Amy M. Starr Chief Office of Capital Markets Trends Division of Corporation Finance

January 23, 2014

Via E -mail
Tom Naratil
Group Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland

Re: UBS AG
Form 20 -F for the Fiscal Year Ended December 31, 2011
Filed March 15, 2012
Form 20 -F for the Fiscal Year Ended December 31, 2012
Filed March 14, 2013
File No. 001-15060

Dear Mr. Naratil :

We have completed our review of your filings. We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal secur ities laws of the United States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules requ ire.

Sincerely,

 /s/ Stephanie J. Ciboroski

 Stephanie Ciboroski
Senior Assistant Chief Accountant

CORRESP
1
filename1.htm

CORRESP

 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

 www.ubs.com

 Ms. Stephanie Ciboroski

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street, NE

 Washington DC 20549-1090

 17 January 2014

UBS AG

 Form 20-F for the Fiscal Years Ended
December 31, 2012 and 2011

 Filed March 14, 2013 and March 15, 2012

Form 6-K filed April 30, 2013; October 30, 2012 and July 31, 2012

Responses dated September 10, 2012; February 28, 2013; April 29, 2013 and September 30, 2013

File No. 001-15060

 Dear Ms Ciboroski:

We respectfully submit a follow-up response to Comment No. 7 of the Comment Letter dated September 5, 2013 (the “Comment Letter” and
individually, the “Comment”) from the Staff of the Securities and Exchange Commission relating to (a) Form 20-F for the Fiscal Year Ended December 31, 2012, filed March 14, 2013 (the “2012 Form 20-F”) and
(b) Form 6-K filed April 30, 2013 (the “Q2 2013 Form 6-K”) of UBS AG (“UBS”). The Comment is a continuation of matters first raised by the Staff in its comment letter dated August 10, 2012 relating to Form 20-F for
the Fiscal Year ended December 31, 2011 and Form 6-K filed July 31, 2012, which later expanded to include Form 6-K filed October 30, 2012 (the “Prior Filings”) as a result of the Staff’s comment letter dated
January 30, 2013. While the Comment Letter only referenced our 2012 Form 20-F and Q2 2013 Form 6-K, the Staff has not yet advised that it has closed its review of the Prior Filings and therefore we consider it to be open. For your convenience,
we have included the Comment below but we have not included our prior response to the Comment in our response letter dated September 30, 2013.

Form 20-F for the Fiscal Year Ended December 31, 2012

Notes to the consolidated financial statements

Note 23 – Provisions and contingent liabilities, page 375

 UBS AG is a public company
incorporated with limited liability in Switzerland domiciled in the Canton of Basel-City and the Canton of Zurich respectively registered at the Commercial Registry offices in those Cantons with Identification No: CH-270.3.004.646-4 and having
respective head offices at Aeschenvorstadt 1, 4051 Basel and Bahnhofstrasse 45, 8001 Zurich, Switzerland and is authorised and regulated by the Financial Market Supervisory Authority in Switzerland. Registered in the United Kingdom as a foreign
company with No: FC021146 and having a UK Establishment registered at Companies House, Cardiff, with No: BR 004507. The principal office of UK Establishment: 1 Finsbury Avenue, London EC2M 2PP. In the United Kingdom, UBS AG is authorised by the
Prudential Regulation Authority and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are
available from us on request.

 UBS AG

Form 20-F for the Fiscal Years Ended December 31, 2012 and
2011

 Filed March 14, 2013 and March 15, 2012

 Form 6-K
filed April 30, 2013; October 30, 2012 and July 31, 2012

 Responses dated September 10, 2012; February 28, 2013; April 29, 2013 and September 30, 2013

File No. 001-15060

17 January 2014

 Page 2

 b) Litigation, regulatory and similar matters, page 375

Comment 7

 We note your disclosure at the top of page
376 explaining the reasons that you do not believe an aggregate estimate for your litigation, regulatory and similar matters as a class of contingent liabilities is practicable. Given the response to comment 22 in your response letter dated
September 10, 2012 that you are able to estimate the possible financial effects beyond the level of current reserves established for certain cases but not others, we believe that this fact should be disclosed along with your estimate of the
possible financial effects, which may be aggregated for all of the litigation matters for which you are able to make such an estimate. Such aggregated disclosure should mitigate your concern that providing these estimates could seriously prejudice
your position in these matters. Alternatively, and if true, you could include a statement that the possible financial effects beyond the level of current reserves established would not have a material impact on your statement of financial condition,
operations and cash flows. Please provide us with your proposed disclosure, and tell us whether aggregation of such amounts by business division is practicable.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

* * * * * * *

 We appreciate the opportunity to
provide you with this additional information. If you wish to discuss any of our responses or require further information, please do not hesitate to contact Todd Tuckner at +1 203 719 0381 (todd.tuckner@ubs.com).

Very truly yours,

 UBS AG

 /s/ Tom Naratil

 Tom Naratil

 /s/ Todd Tuckner

 Todd Tuckner

Group CFO

Group Finance COO

 UBS AG is a public company
incorporated with limited liability in Switzerland domiciled in the Canton of Basel-City and the Canton of Zurich respectively registered at the Commercial Registry offices in those Cantons with Identification No: CH-270.3.004.646-4 and having
respective head offices at Aeschenvorstadt 1, 4051 Basel and Bahnhofstrasse 45, 8001 Zurich, Switzerland and is authorised and regulated by the Financial Market Supervisory Authority in Switzerland. Registered in the United Kingdom as a foreign
company with No: FC021146 and having a UK Establishment registered at Companies House, Cardiff, with No: BR 004507. The principal office of UK Establishment: 1 Finsbury Avenue, London EC2M 2PP. In the United Kingdom, UBS AG is authorised by the
Prudential Regulation Authority and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are
available from us on request.

CORRESP
1
filename1.htm

CORRESP

 UBS

 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

www.ubs.com

 Ms. Stephanie Ciboroski

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street, NE

 Washington DC 20549-1090

 30 September 2013

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. §200.83

UBS AG

 Form 20-F for the Fiscal Year Ended
December 31, 2012

 Filed March 14, 2013

Form 6-K filed April 30, 2013

 Responses dated
February 28, 2013 and April 29, 2013

 File No. 001-15060

Dear Ms Ciboroski:

 We respectfully submit the responses set
forth below to the Comment Letter dated September 5, 2013 (the “Comment Letter” and individually or collectively “Comments”) from the Staff of the Securities and Exchange Commission relating to (a) Form 20-F for the
Fiscal Year Ended December 31, 2012, filed March 14, 2013 (the “2012 Form 20-F”) and (b) Form 6-K filed April 30, 2013 (the “Q2 2013 Form 6-K”) of UBS AG (“UBS”). For your convenience, we have set
out the text of each Comment contained in the Comment Letter, followed by our response.

 Form 20-F for the Fiscal Year Ended December 31, 2012

 General

 Comment 1

Please tell us about any contacts with Syria, Sudan and Cuba since your letters to us dated February 18, 2011 and June 6, 2011. We note that
Byblos Bank and Mashreq Bank list you as a correspondent bank and Byblos Bank has offices and branches in Syria and Sudan, and Mashreq Bank has offices and branches in Sudan. We note that your website lists the Caribbean as one of your markets, and
Cuba is in the Caribbean. As you know, Syria Sudan and Cuba are designated by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. Please describe to us the nature and extent of
your past, current, and anticipated contacts with Syria, Sudan and Cuba, whether through subsidiaries, affiliates, customers, or other

 UBS AG is a public company
incorporated with limited liability in Switzerland domiciled in the Canton of Basel-City and the Canton of Zurich respectively registered at the Commercial Registry offices in those Cantons with Identification No: CH-270.3.004.646-4 and having
respective head offices at Aeschenvorstadt 1, 4051 Basel and Bahnhofstrasse 45, 8001 Zurich, Switzerland and is authorised and regulated by the Financial Market Supervisory Authority in Switzerland. Registered in the United Kingdom as a foreign
company with No: FC021146 and having a UK Establishment registered at Companies House, Cardiff, with No: BR 004507. The principal office of UK Establishment: 1 Finsbury Avenue, London EC2M 2PP. In the United Kingdom, UBS AG is authorised by the
Prudential Regulation Authority and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are
available from us on request.

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 2
 of 13

direct or indirect arrangements. Your response should describe any products or services you have provided to Syria, Sudan or Cuba directly or indirectly, and any agreements, commercial
arrangements, or other contacts with the governments of Syria, Sudan and Cuba or entities controlled by those governments.

 *** CONFIDENTIAL TREATMENT
REQUESTED UNDER RULE 83 ***

 Comment 2

 Please
discuss the materiality of any contacts with Syria, Sudan or Cuba described in response to the foregoing comment, and whether those contacts constitute a material investment risk for your security holders. You should address materiality in
quantitative terms, including the approximate dollar amounts of any associated revenues, assets, and liabilities for the last three fiscal years and the subsequent interim period. Also, address materiality in terms of qualitative factors that a
reasonable investor would deem important in making an investment decision, including the potential impact of corporate activities upon a company’s reputation and share value. Various state and municipal governments, universities, and other
investors have proposed or adopted divestment or similar initiatives regarding investment in companies that do business with U.S.-designated state sponsors of terrorism. Your materiality analysis should address the potential impact of the investor
sentiment evidenced by such actions directed toward companies that have operations associated with Syria, Sudan and Cuba.

 *** CONFIDENTIAL TREATMENT
REQUESTED UNDER RULE 83 ***

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 3
 of 13

 *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 4
 of 13

 Risk management and control – Credit risk, page 136

Exposures to selected Eurozone countries, page 150

Comment 3

 We note the response to comment 18 in your
response letter dated February 28, 2013. As previously requested, please revise your disclosure in future filings to quantify the amount of indexed or tranched purchased credit derivatives included in your tabular disclosure.

The amount of Trading inventory Net long per issuer exposure included in the referenced tabular disclosure that arises from multi-name credit derivatives is
insignificant in the context of the current total exposure. If this amount becomes material in future filings, we will revise our quantitative disclosure accordingly.

Notes to the consolidated financial statements

Note 23 – Provisions and contingent liabilities, page 375

Comment 4

 We note the response to comment 5 in your
response letter dated April 29, 2013. Please revise your disclosure in future filings to quantify the portion of your restructuring provisions related to onerous lease contracts versus the portion related to severance costs. Further, please
consider disclosing personnel related provisions as a separate class from onerous lease provisions in future filings to the extent that the liabilities or changes in the liabilities become material.

Starting with our Q3 2013 Form 6-K, we will quantify the portion of the restructuring provision related to onerous lease contracts and the portion related to
severance costs. To the extent that the liabilities or changes in the liabilities for these portions become material, we will consider disclosing them as separate classes in future filings.

b) Litigation, regulatory and similar matters, page 375

Comment 5

 We note the response to comment 8 in your
response letter dated February 28, 2013. We also understand from our conference call on April 4, 2013, that you are able to determine the expected timing of outflows of economic benefits in some circumstances. This fact should be disclosed
along with the expected timing of any outflows of economic benefits for your litigation and regulatory matters provision class for which you are able to make such an estimate, as well as information regarding the amount of your provisions covered by
such expected timing disclosure. Please provide us with your proposed disclosure, and tell us whether disaggregation of such disclosures by business division is practicable.

We are able to estimate the expected timing of outflows in limited circumstances, such as when we have entered into a settlement agreement and the related
outflow is scheduled to occur on a later date or in installments on several dates. In the overwhelming majority of cases, as we have stated in the introduction to our litigation note and in response to previous SEC Comments, there are too many
unknown factors to make such a determination. These include whether a matter will be settled, how long settlement negotiations would take to reach a conclusion, the timing and outcome of judicial decisions, the likelihood of appeal by UBS or by

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 5
 of 13

plaintiffs and whether an appeal would have the effect of staying the enforcement of a judgment. By aggregating the expected outflows where we are able to estimate timing, in principle we
could make a statement such as:

 With respect to certain litigation, regulatory and similar matters as to which we have established
provisions, we are able to estimate the expected timing of outflows. Of the aggregate amount of the expected outflows for which we are able to estimate expected timing, we estimate [approximately half/one-third/ …] to occur [over the next
             months], and the remainder to occur [over the next              to
             months].

 We do not, however, believe such disclosure would be useful to
investors, and there is an irreducible risk that it could be over-interpreted and misunderstood. Such outflows have not in the past been material in the context of our extremely high level of liquidity and with a Basel III liquidity coverage ratio
of 114% and a management liquidity coverage ratio of 160% as of 30 June, 2013, we have substantial liquidity available to meet numerous outflows, including those related to contingent liabilities. We believe that it is neither meaningful nor
helpful for investors to consider the immaterial effect of the timing of these outflows, as opposed to potentially important effects on profits or losses, capital ratios and (where applicable) reputation or business strategy. For this reason, we
propose to provide the requested disclosure only where the amount of the expected outflows as to which timing is estimable may be material to our liquidity position. So long as we believe that the effect on our liquidity is clearly immaterial, we
propose the following disclosure:

 With respect to certain litigation, regulatory and similar matters as to which we have established
provisions, we are able to estimate the expected timing of outflows. However, the aggregate amount of the expected outflows for those matters for which we are able to estimate expected timing is immaterial relative to our current and expected levels
of liquidity over the relevant time periods.

 Comment 6

We note the response to comment 3 in your response letter dated April 29, 2013 as well as your responses to comments 21 and 22 in your response letter
dated September 10, 2012. Please revise your disclosure in future filings to clearly describe how you evaluate whether both a provision and a contingent liability can arise from the same set of circumstances and clearly indicate that, with the
exception of certain limited situations, you believe these to be mutually exclusive concepts.

 Starting with our Q3 2013 Form 6-K, we will expand our
disclosure as follows (additional wording in italics):

 The Group makes provisions for such matters brought against it when, in the
opinion of management after seeking legal advice, it is more likely than not that the Group has a present legal or constructive obligation as a result of past events, it is probable that an outflow of resources will be required, and the amount can
be reliably estimated. If any of those conditions is not met, such matters result in contingent liabilities. Consequently, a matter arising from a single set of circumstances results in either a provision or a contingent liability, but not both,
except in limited cases (for example, where two separate matters arise from the same set of circumstances).

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 16 September 2013

 Page
 6
 of 13

 Comment 7

We note your disclosure at the top of page 376 explaining the reasons that you do not believe an aggregate estimate for your litigation, regulatory and
similar matters as a class of contingent liabilities is practicable. Given the response to comment 22 in your response letter dated September 10, 2012 that you are able to estimate the possible financial effects beyond the level of current
reserves established for certain cases but not others, we believe that this fact should be disclosed along with your estimate of the possible financial effects, which may be aggregated for all of the litigation matters for which you are able to make
such an estimate. Such aggregated disclosure should mitigate your concern that providing these estimates could seriously prejudice your position in these matters. Alternatively, and if true, you could include a statement that the possible financial
effects beyond the level of current reserves established would not have a material impact on your statement of financial condition, operations and cash flows. Please provide us with your proposed disclosure, and tell us whether aggregation of such
amounts by business division is practicable.

 As you have noted, we have explained in our litigation note the reasons for our conclusion that it is
not practicable to provide an aggregate estimate of the possible financial effects of litigation, regulatory and similar matters as a class of contingent liabilities. For certain individual cases, such an estimate would be possible but for most
if not all cases its disclosure would be seriously prejudicial. As you suggest, this risk may be mitigated by presenting an aggregate disclosure of the total estimate for all matters for which such estimation is practicable, provided that we do
not specify which matters are included or excluded. While such an estimate would likely be practicable, the possibility of a serious prejudicial effect would be magnified if we were to disclose a breakdown of such an aggregate estimate by
reporting segment. Certain segments are subject to only one or a very small number of major cases, a fact that will be made very apparent if we provide a divisional breakdown for the significant matters as your Comment 8 suggests.

Although it is possible to make the suggested aggregate disclosure at Group level, we continue to believe that this could be misconstrued by investors,
analysts, or other users (such as journalists). We would have to disclose that the estimate pertains to a subset of matters to which we are exposed, but it would not be possible to provide a meaningful indication of the scope or significance of
the excluded subset, which would likely include many of our potentially more significant matters. Users could falsely assume (despite including cautionary wording) that certain matters are within (or excluded from) the scope of the disclosed
estimate. It is important to note that certain analysts and journalists have expressed their own views concerning the exposure of UBS and other financial institutions to significant matters such as RMBS/loan putbacks and LIBOR. While we do
not necessarily agree with the assessments or the methodologies employed in the analyses that have been published, we are concerned that our disclosure of an aggregate estimate covering an unspecifi

CORRESP
1
filename1.htm

CORRESP

 UBS

UBS AG

Postfach

CH-8098 Zurich

Tel +41-44-234 11 11

www.ubs.com

 Ms. Stephanie Ciboroski

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 US Securities and Exchange Commission

 Washington,
DC 20549

 September 6, 2013

Re:
UBS AG Form 20-F for the fiscal year ended December 31, 2012

Filed March 14, 2013

Form 6-K filed April 30, 2013

Responses dated February 28, 2013 and April 29, 2013

File No. 001-15060

 Dear Ms. Ciboroski:

We have received your letter dated September 5, 2013, outlining comments from your office with respect to certain issues raised by the captioned filings
of UBS AG and our responses to earlier questions raised by the Staff.

 We are working diligently on preparing written responses to the several issues
raised. We expect that this process will take more than the ten business days within which you have requested a response, because of the need to investigate underlying facts and to discuss the issues raised, and the commitments as to future
disclosure that the SEC is requesting us to make, internally among numerous senior members of management.

 We expect to be in a position to supply our
full response to your comments by September 30, 2013.

 Please contact us if you have any concerns about this.

Very truly yours,

 /s/ Louis Eber

 /s/ Sarah Starkweather

Louis Eber

Sarah Starkweather

Group Managing Director

Executive Director

September 5 , 2013

Via E -mail
Tom Naratil
Group Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland

Re: UBS AG
Form 20 -F for the Fiscal Year Ended December 31, 2012
Filed March 14, 2013
Form 6 -K filed April 30, 2013
Response s dated February 28, 2013 and April 29, 2013
File No. 001-15060

Dear Mr. Naratil :

We have reviewed your filing s and response s and have the following comments.
In some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter within ten business days by prov iding the requested
information  or by advising us when you will provide the requested response.   If you d o not
believe our comments apply to your facts 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 E nded Dec ember 31, 2012

General

1. Please tell us about any contacts with Syria, Sudan and Cuba since your letters to us
dated February 18, 2011 and June 6, 2011.  We note that Byblos Bank and Mashreq  Bank
list you as a correspondent bank and Byblos Bank has offices and branches in Syria and
Sudan, and Mashreq Bank has offices and branches in Sudan.  We note that your website
lists the Caribbean as one of your markets, and Cuba is in the Caribbean.  As  you know,
Syria Sudan and Cuba are designated by the U.S. Department of State as state sponsors of
terrorism, and are subject to U.S. economic sanctions and export controls.  Please
describe to us the nature and extent of your past, current, and anticipat ed contacts with

Tom Naratil
UBS AG
September 5, 2013
Page 2

 Syria, Sudan and Cuba, whether through subsidiaries, affiliates, customers, or other direct
or indirect arrangements.  Your response should describe any products or services you
have provided to Syria, Sudan or Cuba directly or indirectly,  and any agreements,
commercial arrangements, or other contacts with the governments of Syria, Sudan and
Cuba or entities controlled by those governments .

2. Please discuss the materiality of any contacts with Syria, Sudan or Cuba described in
response to th e foregoing comment, and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabili ties for the last three fiscal years and the subsequent interim period .  Also, address
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.  Various state and municipal
governments, universities, and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies that do business with U.S. -
designated state sponsors of terrorism.  Your materiality analysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Syria, Sudan and Cuba .

Risk management a nd control – Credit risk, page 136

Exposures to selected Eurozone countries, page 150

3. We note the response to comment 18 in your response letter dated February 28, 2013.  As
previously requested, please revise your disclosure in future filings to quantify the
amount of indexed or tranched purchased credit derivatives included in your tabula r
disclosure.

Notes to the consolidated financial statements

Note 23 – Provisions and contingent liabilities, page 375

4. We note the response to comment 5 in your response letter dated April 29, 2013.  Please
revise your disclosure in future filings to q uantify the portion of your restructuring
provisions related to onerous lease contracts versus the portion related to severance costs.
Further, please consider disclosing personnel related provisions as a separate class from
onerous lease provisions in fu ture filings to the extent that the liabilities or changes in the
liabilities become material.

Tom Naratil
UBS AG
September 5, 2013
Page 3

 b) Litigation, regulatory and similar matters, page 375

5. We note the response to comment 8 in your response letter dated February 28, 2013.  We
also understa nd from our conference call on April 4, 2013, that you are able to determine
the expected timing of outflows of economic benefits in some circumstances.   This fact
should be disclosed along with the expected timing of any outflows of economic benefits
for your litigation and regulatory matters provision class for which you are able to make
such an estimate, as well as information regarding the amount of your provisions covered
by such expected timing disclosure.   Please provide us with your proposed disclos ure,
and tell us whether disaggregation of such disclosures by business division is practicable.

6. We note the response to comment 3 in your response letter dated April 29, 2013 as well
as your responses to comments 21 and 22 in your response letter dated S eptember 10,
2012.  Please revise your disclosure in future filings to clearly describe how you evaluate
whether both a provision and a contingent liability can arise from the same set of
circumstances and clearly indicate that, with the exception of certa in limited situations,
you believe these to be mutually exclusive concepts.

7. We note your disclosure at the top of page 376 explaining the reasons that you do not
believe an aggregate estimate for your litigation, regulatory and similar matters as a clas s
of contingent liabilities is practicable.  Given the response to comment 22 in your
response letter dated September 10, 2012 that you are able to estimate the possible
financial effects beyond the level of current reserves established for certain cases b ut not
others, we believe that this fact should be disclosed along with your estimate of the
possible financial effects, which may be aggregated for all of the litigation matters for
which you are able to make such an estimate.  Such aggregated disclosure should
mitigate your concern that providing these estimates could seriously prejudice your
position in these matters.  Alternatively, and if true, you could include a statement that
the possible financial effects beyond the level of current reserves establ ished would not
have a material impact on your statement of financial condition, operations and cash
flows.  Please provide us with your proposed disclosure, and tell us whether aggregation
of such amounts by business division is practicable.

8. We note the response to comment 2 in your response letter dated April 29, 2013.  Please
confirm that you will disclose this information in future filings in order to provide a link
between the segment level provision rollforward presented on page 376 and the narrative
discussion of the 18 matters discussed below that table.

9. We note the response to comment 23 in your response letter dated September 20, 2012.
It appears from your response that you rely on the exception in paragraph 92 of IAS 37
on a regular basis as r ationale for not disclosing certain facts related to litigation and
regulatory matters.  Again, we point out that this exemption should be used in extremely
rare cases, and that when it is used you are still obligated to disclose certain information

Tom Naratil
UBS AG
September 5, 2013
Page 4

 relate d to the general nature of the dispute(s) together with the fact that, and reason why,
the information has not been disclosed.  Therefore, we again ask that you tell us and
revise future filings to explicitly identify the matters to which you are applying the
prejudicial exemption, and  state, on a case-by-case basis , the general nature of the
dispute(s), the type of information that has been omitted, and reason(s) why this
information has not been disclosed.  Please provide us with your proposed disclosures .

6. Claims related to sales of residential mortgage -backed securities and mortgages, page 377

10. We note the responses to comment 21 from your letter dated February 28, 2013 and
comment 4 from your letter dated April 29, 2013.  Please provide us with a more detailed
analysis regarding the specific legal strategy you referred to in your April 29, 2013
response for which you requested confidential treatment.

Note 31 – Equity participation and other compensation plans, page 428

Deferred Contingent Capital  Plan (DCCP), page 429

11. We note your disclosure herein as well as on page 290 regarding the issuance of deferred
compensation awards under the DCCP during 2012.  Please confirm that the fair value of
these awards is re -measured at each balance sheet date, and clarify how the fair value of
such awards is determined.  In this respect, describe the significant assumptions used and
specifically explain how the contingent interest payments (which are contingent on
achieving pre -tax profit in a given period) are factored into your fair value determination.

Form 6 -K filed April 30, 2013

Notes to the interim consolidated financial statements

Note 1 – Basis of accounting, IFRS 10 Consolidated Financial Statements, page 87

12. We note that upon the adoption of IFRS 10 on January 2, 2013 you consolidated certain
entities that previously were not consolidated and deconsolidated certain entities that
were previously consolidated.  Please address the following:

 For each entity (or type of entity) that was newly consolid ated or deconsolidated
as a result of the adoption of IFRS 10, summarize the key factors that were
considered in reaching your conclusion to consolidate/deconsolidate those entities
and cite the specific guidance in IFRS 10 that you relied upon in forming your
conclusion.
 Revise your disclosure in future filings to clarify how you applied the transition
provisions set forth in paragraphs C4 – C6 of IFRS 10.

Tom Naratil
UBS AG
September 5, 2013
Page 5

  With respect to the deconsolidation of certain entities that issue preferred
securities, explain how you determined that the subordinated notes (with the
exception of CHF 1.2 billion classified as a liability) should be classified as
“equity attributable to preferred note holders”. In this regard, provide a detailed
analysis explaining why you believe equ ity classification is appropriate for these
instruments and explain how you determined that the equity and profit associated
with these instruments should be presented outside of that which is attributable to
UBS shareholders.  Please also provide referenc es to the relevant authoritative
literature.

You may contact Brittany Burris  at (202) 551 -3572 or Angela Connell at (202) 551 -3426
if you have questions regarding comments on the financial s tatements and related matters.
Please contact Jennifer Hardy  at (202) 551 -3676 with any other questions.

Sincerely,

 /s/ Angela Connell for

 Stephanie Ciboroski
Senior Assistant Chief Accountant

CORRESP
1
filename1.htm

CORRESP

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

 www.ubs.com

 UBS AG -
1

 Ms. A. Connell

 Division of Corporation Finance

 Securities and Exchange Commission

100 F Street, NE

 Washington DC 20549-1090

 29 April 2013

 UBS AG HAS
CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN

 ACCORDANCE WITH 17 C.F.R §200.83

UBS AG

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

 Filed March 15, 2012

 Form 20-F for the Fiscal Year Ended December 31, 2012

 Filed March 14, 2013

 Dear Ms. Connell:

 We
respectfully submit the information below in response to the requests (the “requests”) made by the Staff of the Securities and Exchange Commission (the “Staff”) during the calls held on April 4, 2013 and April 15, 2013
relating to the Provisions and Contingent liabilities disclosures in: (a) the annual report on Form 20-F for the fiscal year ended December 31, 2011 (the “2011 Form 20-F”) and (b) the annual report on Form 20-F for the
fiscal year ended December 31, 2012 (the “2012 Form 20-F”) of UBS AG (“UBS”). For your convenience, we have set out our understanding of the requests in the comment boxes below, followed by our response.

Comment 1

 Please explain why
litigation is included in both the Operational risks class and the Litigation, regulatory and similar matters class. Please explain how those two types of litigation are different and thus included in those two classes.

In footnote 1 to the Provisions table on page 341 of our 2011 Form 20-F, we disclosed that the Operational risks class “includes provisions for
litigation resulting from security risks and transaction processing risks”. Upon further review, we identified that the matters reported in this class were not subject to litigation during 2011 or in subsequent periods, rendering the
reference to ‘litigation’ irrelevant. Accordingly, in future filings, we will amend the description of this class in the footnote to state: “Comprises provisions for losses resulting from security risks and transaction
processing risks”. All litigation matters are reflected in the Litigation, regulatory and similar matters class.

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 2

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 2
 of 7

 Comment 2

 Page 376 of 2012 Form 20-F includes the table titled, “Provisions for litigation, regulatory and similar matters by segment.” Please tell us how the 18 items described in section b) of Note
23 of the 2012 Form 20-F link to each of the segments in the specified roll-forward table.

 Below are all of the 18 items described in
section b) of Note 23 of the 2012 Form 20-F, aligned to the relevant reporting segment or to Corporate Center – Core Functions:

 Wealth Management

•   Inquiries regarding cross-border wealth management businesses

 •   Madoff

 •   Swiss
retrocessions*

 Wealth Management Americas

 •   Lehman principal
protection notes

•   Puerto Rico

 Investment Bank

 •   SinoTech Energy
Limited**

•   Unauthorized trading incident**

 •   Greater Southwestern
Funding

 Retail & Corporate

 •   Swiss
retrocessions*

 Corporate Center - Core Functions

•   Municipal bonds**

 •   Claims related to
UBS disclosure

•   LIBOR and other benchmark rates

 •   Banco UBS Pactual
tax indemnity

 Corporate Center - Non-core & Legacy
Portfolio

•   Auction rate securities

 •   Matters related to
the financial crisis

•   Claims related to sales of residential mortgage-backed securities and
mortgages

•   Transactions with Italian public sector entities

 •   HSH Nordbank AG
(HSH) **

•   Kommunale Wasserwerke Leipzig GmbH (KWL)

*
 Allocated in part to Wealth Management and in part to Retail & Corporate.

**
 When reviewing these matters as part of the preparation for the Q1 2013 report, we determined that these matters no longer require separate disclosure

 Comment 3

Paragraph 88 of IAS 37 indicates that “Where a provision and a contingent liability arise from the same set of circumstances, an entity makes the
disclosures required by paragraphs 84-86 in a way that shows the link between the provision and the contingent liability”. In our call on 4 April 2013, you indicated that a set of circumstances gives rise to either a provision or a
contingent liability but not both. You also indicated that this was consistent with IAS 37 interpretive guidance from certain accounting firms. Please provide us with an additional explanation of your accounting position and describe to us how it is
consistent with paragraph 88 of IAS 37.

 IAS 37.13 distinguishes between provisions and contingent liabilities using the following terms:

(a)
provisions – which are recognized as liabilities (assuming that a reliable estimate can be made) because they are present obligations and it is probable that an
outflow of resources embodying economic benefits will be required to settle the obligations; and

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 3

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 3
 of 7

(b)
contingent liabilities – which are not recognized as liabilities because they are either:

(i)
possible obligations, as it has yet to be confirmed whether the entity has a present obligation that could lead to an outflow of resources embodying economic
benefits; or

(ii)
present obligations that do not meet the recognition criteria in this Standard (because either it is not probable that an outflow of resources embodying economic
benefits will be required to settle the obligation, or a sufficiently reliable estimate of the amount of the obligation cannot be made).

 The paragraph quoted above demonstrates that provisions and contingent liabilities are considered mutually exclusive concepts. Therefore, when assessing the facts and circumstances of a single transaction
or a group of similar transactions that constitute a single unit of account, we do not believe that a provision and a contingent liability can arise in respect of a single unit of account, except with respect to joint and several liability (as
described in IAS 37.29 and addressed in our response to Comment 4 below) and other limited circumstances. In those cases, the requirements set out in IAS 37.88 are applicable. This view is supported and further clarified by the guidance set out in
paragraph 3.12.110.40 of the 8th edition 2011/2012 of KPMG’s Insights into IFRS, which states:

 “In our view,
when a provision is measured at its best estimate, which is less than the amount that could be payable, the difference between the two amounts is not a contingent liability….This is because the unit of accounting is the obligation. The
uncertainty regarding the amount of the costs to be incurred is reflected in the measurement although disclosure of the uncertainty regarding measurement should be considered. We believe that there is no separate obligation or past event for the
unrecognized portion of the range of possible costs.”

 Where a matter gives rise to more than one potential exposure which are
assessed as multiple units of account, then both a provision and a contingent liability could arise within the same matter, as envisaged in IAS 37.88. For example, on page 376 of our 2012 Form 20-F, we disclose information on a matter relating
to Municipal bonds, which has been disclosed in our financial statements for a number of years. Although this matter arises from one set of circumstances (being alleged bid-rigging relating to municipal bond
financings), the legal actions against UBS include both regulatory and civil charges and so they need to be assessed as separate units of account. In our 2012 Form 20-F, UBS announced a USD 140.3 million
settlement with certain regulators. Separate from this, but closely related and arising from the same set of circumstances, we also disclosed a number of class actions seeking damages. Because the accounting assessment for these two components
is different, they could (absent seriously prejudicial considerations), give rise to disclosure of a related provision and contingent liability for the same matter. Similar considerations would apply, for example, to the Auction rate
securities matter.

 Comment 4

Please provide us with a detailed response regarding how your accounting position regarding loan repurchase demands is consistent with paragraphs
53—58 of IAS 37 Provisions, Contingent Liabilities and Contingent Assets. In your response, please indicate whether you are liable for loan repurchase demands if originators-indemnitors fail to pay. If applicable, please explain why you believe
that indemnity payments are virtually certain of being received. If you have not recognized a provision for loan repurchase demands that are expected to be reimbursed by the originator-indemnitor, please quantify the effect of that unrecognized
amount with regards to the provision recognized as of 31 December 2012.

 *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 4

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 4
 of 7

 *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 5

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 5
 of 7

 *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 6

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 6
 of 7

 *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

Comment 5

 Provide the break-out for
the balance of restructuring provisions between personnel related provisions and onerous lease provisions.

 The following table provides
the information requested:

CHF million

31 December 2011

31 December 2012

 Personnel related provisions

163

243

 Onerous lease provisions

304

268

 Total restructuring provisions

467

511

 CONFIDENTIAL TREATMENT REQUESTED BY UBS AG -
 7

 UBS AG

 Form 20-F for the
Fiscal Year Ended

 December 31, 2011 filed March 15, 2012

 Form 20-F for the Fiscal Year Ended

 December 31, 2012 filed March 14, 2013

 29 April 2013

  Page
 7
 of 7

 Comment 6

 Provide roll-forward information for the comparative period for the “Provision for claims related to sales of residential mortgage-backed securities and mortgages” table on page 379 of the
2012 Form 20-F.

 The following table provides the information requested:

USD million

Year
ended
31 December 2011

 Balance at the beginning of the year

97

 Increase in provision recognized in the income statement

40

 Provision used in conformity with designated purpose

(32
)

 Balance at the end of the year

104

 * * * * * * *

 We appreciate the opportunity to provide you with this additional information. If you wish to discuss any of our responses or require further information, please do not hesitate to contact either Todd
Tuckner at +1 203 719 0381 (todd.tuckner@ubs.com) or Alex Brougham at +44 207 567 7425 (alex.brougham@ubs.com).

 Very truly yours,

UBS AG

Tom Naratil

Todd Tuckner

Group CFO

Group Finance COO

CORRESP
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Correspondence

 March 7, 2013

 Ms. Amy L. Starr

 Chief Office of Capital Markets Trends

Division of Corporation Finance

 US Securities
and Exchange Commission

 Washington, DC 20549

Re:
UBS AG

 424 Prospectuses
relating to Registration Statement on Form F-3ASR

 Filed January 11, 2012

File No. 333-178960

 Dear Ms.
Starr:

 Thank you for your letter of February 21, 2013. We have reviewed your comments and confirm that we will implement changes to
future prospectus supplements to reflect those comments. We are currently engaged in drafting efforts to revise and conform our disclosure. Due to the wide variety of notes we offer, as well as required changes to our
internal operating procedures, we expect to implement changes over a period of time.

 Please do not hesitate to contact us if you have
questions or comments or would like to discuss further the contents of this letter.

 Very truly yours,

 UBS AG

 By: /s/ Gordon S.
Kiesling

Gordon S. Kiesling

 Executive Director

CORRESP
1
filename1.htm

CORRESP

 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

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

 28 February 2013

 UBS AG

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

 Filed March 15, 2012

 Forms 6-K filed July 31, 2012 and October 30, 2012

 Response dated
September 10, 2012

 File No. 001-15060

 Dear Ms. Ciboroski:

 We respectfully submit the responses set forth below to the Comment
Letter dated January 30, 2013 (the “Comment Letter” and individually or collectively “Comments”) from the Staff of the Securities and Exchange Commission relating to (a) the annual report on Form 20-F for the fiscal
year ended December 31, 2011 (the “2011 Form 20-F”), (b) the second quarter 2012 report on Form 6-K (the “Q2 2012 Form 6-K”) and (c) the third quarter 2012 report on Form 6-K (the “Q3 2012 Form 6-K”) of
UBS AG (“UBS”). For your convenience, we have set out the text of each Comment contained in the Comment Letter, followed by our response. We are in the final stages of preparing our annual report for the fiscal year ended December 31,
2012, which is expected to be authorized for issue by the Board of Directors on March 7, 2013 and then filed on Form 20-F (the “2012 Form 20-F”). Where relevant, we have included in the relevant responses below our current proposed
disclosure for the 2012 Form 20-F.

 Comment 1

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

 Composition of credit
risk – business divisions, page 120

 Wealth Management & Swiss Bank, page 120

We note your response to prior comment 5. Please provide us with the proposed disclosures that you intend to provide in your future filings to address
our comment.

 We have considered your Comments requesting additional disclosure for our residential real estate loan portfolio with regard
to our process for loan-to-value (“LTV”) ratios at the origination of such loans, quantitative information on our current LTV ratios and the process for calculating current LTV ratios. Our current proposed disclosure on this matter, in the
Composition of credit risk – business divisions section of the 2012 Form 20-F, is below. We believe that this enhanced disclosure addresses these Comments.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15,
2012

 Forms 6-K filed July 31, 2012 and October

 30, 2012

 Response dated September 10, 2012

File No. 001-15060

 28 February 2013

 Page 2 of 22

 “Our largest loan portfolio is our mortgage loan portfolio, which principally comprises loans
within Switzerland which are secured by residential and commercial real estate. These mortgage loans mainly originate from our Retail and Corporate business but also include mortgage loans originating from our Wealth Management business. The
majority of these mortgage loans relate to residential properties that the borrower either occupies or rents out and are full recourse to the borrower.

 We use a scoring model as part of a standardized front-to-back process to support credit decisions for the origination or modification of all Swiss mortgage loans. The two key factors within this model
are an affordability calculation relative to gross income and the loan-to-value ratio (LTV). The calculation of affordability takes into account interest payments, minimum amortization requirements, potential property maintenance costs and, in the
case of properties expected to be rented out, the level of rental income. Interest payments are estimated using a predefined framework, which takes into account the potential for significant increases in interest rates during the lifetime of the
loan.

 Approximately 70% of the Swiss residential mortgage loan portfolio relates to properties occupied by the borrower. For such mortgage
loans, the maximum LTV allowed within the standard approval process is 80%. This is reduced to 60% in the case of vacation properties and luxury real estate. The value assigned by UBS to each property is based on the lowest value determined based on
an internal valuation, the purchase price and, in some cases, an additional external valuation. Valuations of owner-occupied real estate are reviewed and updated throughout the lifetime of the loan, typically using real estate price indices. The
average LTV ratio of this portfolio was approximately 55% at 31 December 2012, compared with 58% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate
collateral even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 63%.

Approximately 30% of the Swiss residential mortgage loan portfolio relates to properties rented out by the borrower. For such mortgage loans, the maximum
LTV allowed within the standard approval process ranges from 60% to 80%, depending on the type of property, the age of the property and the amount of any renovation work required. LTVs are reviewed and updated periodically throughout the lifetime of
the loan. The rental income from properties is reviewed, at a minimum, once every three years, but indications of significant changes in the amount of rental income or the level of vacancy rate can trigger an interim reappraisal. The average LTV
ratio of this portfolio was approximately 58% at 31 December 2012, compared with 59% at 31 December 2011. Over 99% of the aggregate amount of mortgage loans within this portfolio would continue to be covered by the real estate collateral
even if the value assigned to that collateral were to decrease by 20%. Furthermore, these loans are full recourse to the borrower. The average LTV for 2012 of newly originated loans in this portfolio was 56%.”

Comment 2

 Consolidated Financial
Statements, page 284

 Note 1 – Summary of significant accounting policies, page 297

a) Significant accounting policies, page 297

 10) Loans and Receivables – Renegotiated Loans, page 301

 We note your
response to prior comments 14 and 15. Please address the following:

•

 Revise your disclosure in future filings to clarify the differences between loans renegotiated on concessionary terms and loans renegotiated on a
non-concessionary basis in terms of nonperforming classification and method of impairment measurement.

•

 Tell us and revise future filings to disclose whether you monitor or segregate these loans from other non-renegotiated loans within the general
collective loan assessment for purposes of measuring credit losses. If you do not segregate these loans from loans that were not previously renegotiated, please tell us whether you otherwise take into consideration the fact that these loans have
been renegotiated when measuring credit losses.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15,
2012

 Forms 6-K filed July 31, 2012 and October

 30, 2012

 Response dated September 10, 2012

File No. 001-15060

 28 February 2013

 Page 3 of 22

 We have considered your Comments with regard to clarifying the differences between loans renegotiated on
concessionary terms and loans renegotiated on a non-concessionary basis—in terms of non-performing classification and method of impairment measurement. Additionally, we have considered how we treat and monitor these loans within the general
collective loan assessment for purposes of measuring credit losses. Consequently, our current proposed disclosure on this matter in Note 1, the Summary of significant accounting policies section of the 2012 Form 20-F, is as follows:

“A renegotiated loan is defined as a loan that has been subject to restructuring, or for which additional collateral has been requested that was not
contemplated in the original contract.

 Typical key features of terms and conditions granted through renegotiation to avoid default include
the provision of special interest rates, postponement of interest or amortization payments, modification of the schedule of repayments or amendment of loan maturity. There is no change in the effective interest rate following a renegotiation.

 If a loan is renegotiated with concessionary conditions (i.e. new terms and conditions are agreed which do not meet the normal market
criteria for the quality of the obligor and the type of loan), the position is still classified as non-performing and is rated as being in counterparty default. It will remain so until the loan is collected or written off and will be assessed for
impairment on an individual basis.

 If a loan is renegotiated on a non-concessionary basis (e.g. additional collateral is provided by the
client, or new terms and conditions are agreed which meet the normal market criteria for the quality of the obligor and the type of loan), the loan will be re-rated using our regular rating scale. In these circumstances, the loan is removed from
impaired status and therefore included in our collective assessment of loan loss allowances. For the purposes of measuring credit losses, these loans are not segregated within the collective loan loss assessment from other loans which have not been
renegotiated. Management regularly reviews all loans to ensure that each of the criteria contained in the loan agreement continues to be met and that future payments are likely to occur.

 In those situations where the restructuring of a loan results in a fundamental change in the terms and conditions of the loan, the original loan is derecognized and a new loan is recognized. A change is
considered fundamental if the present value of the contractual cash flows (as a proportion of notional) has been changed by 10% or more, or there has been a significant change in the risk profile of the instrument. If a loan is derecognized in these
circumstances, the new loan is measured at fair value at initial recognition. Any allowance taken to date against the original loan is eliminated and is not attributed to the new loan. Consequently, the new loan is not considered impaired and is
included within the general collective loan loss assessment for the purpose of measuring credit losses.”

 Comment 3

Note 16 – Goodwill and intangible assets, page 336

 We note your response to prior comment 16, including the statement that you do not specifically identify the assets and liabilities that make up the excess capital. Please confirm that the carrying
value of each cash generating unit (CGU) includes only those assets that can be attributed directly, or allocated on a reasonable and consistent basis, to each CGU and provide a robust explanation of your asset allocation process. In this regard,
clarify whether you are able to specifically identify the assets that remain in the Corporate Center after allocations (or conversely, whether you are able to specifically identify which assets have been allocated out to the CGUs). If not, please
tell us how you concluded that you met the criteria in paragraphs 76 of IAS 36.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15,
2012

 Forms 6-K filed July 31, 2012 and October

 30, 2012

 Response dated September 10, 2012

File No. 001-15060

 28 February 2013

 Page 4 of 22

 As noted in the Capital Management section of our 2011 Form 20-F, equity is attributed to the businesses
and the Corporate Center (“CC”) after considering their risk exposure, risk-weighted assets (“RWA”) usage, asset size, goodwill and intangible assets. Thus in order to attribute equity under the equity attribution framework
(“EAF”), the assets of each segment (or cash-generating unit (“CGU”)) and the CC are identified. Because we identify the assets attributable to each CGU and the CC, we can confirm that the carrying amount of each respective CGU
and the CC includes only those assets that can be attributed directly or allocated on a reasonable and consistent basis to it.

 We attribute
assets directly to the CGUs and the CC based on the way assets are managed internally, meaning that assets are attributed to the business division (or the CC) that is responsible for managing them and their performance. Hence, that approach is
aligned with our segment reporting pursuant to IFRS 8 Operating Segments as most recently disclosed in our fourth quarter 2012 report on Form 6-K (“the Q4 2012 Form 6-K”).

 As we can identify the assets in the CC, for the purpose of our goodwill impairment testing, we evaluate them to determine whether they represent corporate assets, as described in IAS 36.100-101.
Corporate assets in the CC are identified and allocated to the CGUs on a reasonable and consistent basis. Allocated corporate assets consist of property and equipment, which have been allocated based on actual rates of usage incurred by each CGU.
Other assets in the CC are not deemed to represent corporate assets because they generate cash flows independently of the other CGUs and thus are not allocated (e.g. our multi-currency portfolio of unencumbered, high quality, short-term financial
assets that are managed by Group Treasury). The Legacy Portfolio financial assets in CC also are not allocated for that same reason.1

 As a result
of the process described above, we are able to specifically identify the assets that remain in the CC after allocations. We believe that our attribution and allocation methodology results in an appropriate basis for determining the carrying amount
of each CGU in accordance with IAS 36.76–79.

 Comment 4

 Furthermore, to the extent that you do not identify the specific assets and liabilities directly attributed to each CGU, please tell us how you are able to estimate the cash flows from such CGUs. In
your response, please address why you believe your methodology complies with the guidance in paragraph 77 of IAS 36.

 As explained in our
response to Comment 3, we are able to identify the specific assets for each CGU. Thus we have the requisite information to determine that our attribution and allocation methodology results in an appropriate basis for determining both the recoverable
amount and the carrying amount of our CGUs. Hence, we believe that our methodology complies with the guidance in IAS 36.77.

 Comment 5

 In your response dated September 16, 2011 you noted that one potential shortfall of the equity attribution framework was that the
attribution process will not always result in aggregated attributed equity at the segment level being the same as equity attributed to your shareholders. You further recognized that adjustments would need to be made to ensure that the carrying
amount for purposes of the goodwill impairment test was not less than the equity attributable to shareholders and therefore the net carrying amount of your assets and liabilities, which you believed was consistent with the premise and requirements
of paragraphs 76-79 of IAS 36. Please tell us how your current equity attribution framework, including how it is used in determining the carrying value of your CGUs for purposes of goodwill impairment testing is consistent with your prior response.

1
The Legacy Portfolio was transferred to CC before the end of 2011; its assets consist of financial instruments.

 UBS AG

 Form 20-F for the Fiscal Year Ended

 December 31, 2011 filed March 15,
2012

 Forms 6-K filed July 31, 2012 and October

 30, 2012

 Response dated September 10, 2012

File No. 001-15060

 28 February 2013

 Page 5 of 22

 Please also refer to our response to Comment 3, where we outline our attribution and allocation
methodology which results in an appropriate basis for determining the carrying amount of each CGU in accordance with IAS 36.76–79.

 The
following table

February 21, 2013

Via E -mail
Sarah M. Starkweather
UBS AG
677 Washington Blvd.
Stamford, Connecticut 06901

Re: UBS AG
424 Prospectuses relating to Registration Statement on Form F-3ASR
Filed January 11, 2012
File No. 333-178960

Dear  Ms. Starkweather :

We have reviewed certain of your prospectus supplements for structured note offerings
and your response s to our letter dated April 12, 2012  and considered our subsequent discussions
with you.  We  have a number  of comments  that we have identified below .  Please respond to this
letter within ten business days confirm ing to us that you will comply with our comments  in this
letter and in our prio r letter  in your future prospectus supplements or explaining why you believe
the comment is not appropriate .  Please note that it is possible that we may have additional
comments  on the prospectus supplements you file in the future .

Pricing and Value of Structured Notes

We believe that, similar to the requirements of Regulation S -K Items 201, 501, and 505
for equity securities, the method by which the price of the structured note being offered is
determined through evaluation of its components and the v alue of such components should be
described, particularly since the price and value of the structured note are not readily
determinable from public information regarding your outstanding debt obligations.  In our
discussions, you have described the compone nts of the public offering price of the structured
note and the issuer’s or its affiliates’ estimate of the value of the structured note.  Since you or
your affiliates  develop these valuations, we believe that it is important for investors to
understand th e difference between the original issue price of a structured note and its value as
estimated by you or your affiliate  in structuring the note and determining its pricing (the
“issuer’s valuation”).

Sarah M. Starkweather
UBS AG
February 21 , 2013
Page 2

 Issuer’s Valu ation

In order to clarify the discl osure for investors about the pricing and market value of the
securities, w e believe you should prominently disclose, together with the price of the structured
note as required by Item 501 of Regulation S -K, the issuer’s valuation  of the structured note  on
the cover page of the prospectus.  We believe that investors should be able to understand the
difference between the issuer’s valuation and the original issue price that they are paying for the
structured note.  In order for investors to understand thi s difference in a clear manner , we believe
the issuer’s valuation that is disclosed should not include hedging costs (except in one limited
circumstance described below), underwriting discounts or commissions and other transaction
costs.   In a typical stru ctured note offering, we believe that t he disclosed  issuer’s valuation
should consist of a single number that is comprised of the sum of the issuer’s valuation of the
two components  of the structured note: (1) the fixed income bond and (2) the embedded
derivative (s).  As discussed below, information about hedging and other costs also may be
disclosed.

You may use n arrative disclosure  to explain how you derive the issuer’s valuation  of the
structured note.   For instance, if you include narrative disclosure , you could disclose that the
issuer’s valuation is determined by using internal pricing models .  In that case, it may be
appropriate to narratively describe the pricing models and the relevant inputs and assumptions
used in such models.  As discussed belo w, narrative disclosure should include a discussion of the
risks inherent in your valuation  methodology and related assumptions .

It is our understanding that t he value of the fixed income bond  component of the issuer’s
valuation  may reflect either (i) an interest rate that you determine you are willing to pay to issue
similar debt securities (known as an “internal funding rate”) or (ii) an interest rate that reflects
your secondary market credit spread s.  We understand that the internal funding rate may
represent a discount from your secondary market credit spreads.  We have observed that issuers
typically use an internal funding rate in calculating the value of the fixed income bond in order to
account for higher issuance, operational and ongoing managemen t costs of structured notes in
comparison to those costs for conventional fixed -rate debt, which is generally issued at an
interest rate that reflects secondary market credit spreads .  If the inter nal funding rate is used , we
believe that you should include appropriate disclosure to describe how the use of an internal
funding rate, rather than secondary market credit spreads , impacts the issuer’s valuation of the
structured note.  In addition, we believe that you should disc uss in appropriate risk factor
disclosure the risks that arise because this  difference affects the value of the structured note at
issuance as compared to the price of the structured note in the secondary market.

Sarah M. Starkweather
UBS AG
February 21 , 2013
Page 3

 We have observed  that when issuers value t he embedded derivative component , they use
valuation models that have  various inputs.   To develop these valuation models, issuers use traded
market prices on comparable derivative instruments to derive the inputs for their embedded
derivative valuation mod els (customarily called “mid -market inputs”).  These inputs can be used
to estimate the value of other embedded derivatives that offer terms s imilar to the comparable
traded derivative instruments.   For structured notes, issuers generally make adjustments to the
mid-market inputs to estimate the value of a n embedded  derivative that does not have an
observable market price .  Such inputs are generally determined in the same manner for financial
statement  reporting  purposes.   If you do not use mid -market inputs, we believe you should
disclose this fact, describe what you use, and  the risk that the embedded derivative is being
valued differently than other similar derivatives .

In addition, except in one limited circumstance noted below, we believe the disclosed
valuation of the embedded derivative should not include “hedging costs” or other “transaction
costs” of you or your affiliates arising from the issuance of the notes.  We have observed that
some issuers ma y use only a bidding process with unaffiliated third parties rather than internal
pricing models to value the embedded derivative in the structured note .  If you do not bid  out the
pricing of the embedded derivative to an unaffiliated third party  or you us e an internal pricing
model to value the embedded derivative for any reason , the value of the embedded derivative
should not include  any hedging and other transaction costs  of you or your affiliates .  These costs
should not be included because they are cos ts to you as the issuer separate from the value of the
embedded derivative component.  If you (i)  bid out the pricing of the embedded derivative to an
unaffiliated third party as the sole method of valuing the embedded derivative,  (ii) do not use any
internal pricing model to value the embedded derivative for any reason and (iii) disclose in your
prospectus that you will engage in the derivative transaction with such unaffiliated third party,
then you may use the unaffiliated third party’s bid for valuing t he embedded derivative .  We
understand that the unaffiliated third party’s bid  may already include their hedging costs.   In this
limited  circumstance, your disclosure should indicate that the issuer’s valuation includes the
unaffiliated third party’s estim ated hedging costs as part of its bid price for the embedded
derivative .

Other Costs or Amounts

In addition to the disclosure of the issuer’s valu ation , we believe that as part of your
pricing disclosures you  should include narrative disclosure to exp lain (i) the fees, costs and other
amounts that you add to the issuer’s valu ation  to calculate the original issue price of the
structured notes and (ii) whether those amounts received from investors are used or retained by
you or an affiliate .  As appropri ate, you may quantify such disclosed fees, costs and other
amounts.

Sarah M. Starkweather
UBS AG
February 21 , 2013
Page 4

Timing

Consistent with Securities Act Rule 159, w e believe that information about the issuer’s
valuation  should be conveyed to investors prior  to the time of sale so that they can ma ke an
informed investment decision.  If the structured notes are marketed using a preliminary
prospectus  or preliminary term sheet, and you use a range of the initial offering price or pricing
terms of the structured notes in such materials, then we unders tand you may also have developed
a range of the issuer’s valuation  of the structured notes , which also should be disclosed .  In
addition , you should provide sufficient disclosure in the preliminary prospectus or preliminary
term sheet so that investors can assess the correlation between the range of the original issue
price and the range of the issuer’s valuation .

Risk Factors

Depending upon the facts and circumstances of a particular offering, the p rospectuses for
your structured note offerings may need to include risk factor disclosure1 relating to the pricing
and valuation of the structured notes , as applicable, including:

 the risk that the  issuer’s valu ation  will be less than the original issue price ;
 risks arising from the fact that the embedded derivative is not valued using mid -market
inputs ;
 risks to the effect that the use of an internal funding rate, rather than secondary market
credit spreads, may result in a value of the structured note at issuance that is different
from the price of the st ructured note in the secondary market;
 the risk that secondary market prices will likely be lower than the original issue price
because secondary market prices (i) take into account your secondary market credit
spreads and (ii) exclude your costs of hedgi ng your obligation on the notes, underwriting
discounts and commissions and other transaction costs ;
 any risks arising from the manner in which customer account statement values after
issuance are determined and why these values may be temporarily higher than the
secondary market values of the notes;
 the factors that may affect secondary market prices such as changes in market conditions,
your creditworthiness, and customary bid/ask spreads for similarly sized trades; and
 any conflicts of interest arising from the determination of the structured note price, the
issuer’s valuation, or the sale of the structured notes by an affiliate of the issuer.

1  See Item 503 of Regulation S -K.

Sarah M. Starkweather
UBS AG
February 21 , 2013
Page 5

 Secondary M arket

We note that prospectuses disclose that the issuer or its affiliates  may, but are not
obligated to, make a secondary market in the structured notes.  We have observed that
immediate ly following the issuance of structured  notes, where there is disclosure that issuers or
their affiliates may repurchase the notes, the price a t which the issuer or its affiliates  may
initially repurchase structured notes may exceed the issuer’s valuation, the secondary market
price of the notes , and the value of these notes on customer account statements.  We understand
that this temporary difference may occur because the repurchase price may include
“reimbursement ” of (i) amounts that the issuer will not be using to hedge its future exposures on
the notes, and (ii) other amounts that  the issuer  added to the issuer’s valuation  to determine  the
price of the notes  at initial issuance.

If applicable, w e believe that you should disclose why  the price at which you  or your
affiliates may  initially repurcha se the notes may exceed the secondary market price for the notes.
We also believe that you should disclose whether investors will always receive a higher
repurchase price immediately after the issuance of the notes or whether it is discretionary.
Further , since the  time period  for the temporary price difference  is typically determined at the
time of the  initial pricing of the notes, you should disclose such time period  and the reason for
choosing the time period .  We have observed that sometimes this time  period is referred to as an
“amortization” period.  However, we believe this terminology may confuse investors.  Instead,
we believe you should use clear disclosure to explain to investors the reason for the potential
temporary difference between the repu rchase price, the issuer’s valuation, the secondary market
price, and if applicable, the value on customer account statements.

If you have any questions regarding these comments, please contact me or Raquel Fox at
(202) 551 -3860.

  Sincerely,

  /s/ Amy Starr
  Amy Starr
Chief
Office of Capital Markets Trends
Division of Corporation Finance

CORRESP
1
filename1.htm

CORRESP

 UBS AG

Postfach

 CH-8098 Zurich

 Tel +41-44-234 11 11

Deputy Group General Counsel

 Group Corporate, Transactions & Governance

 Louis Eber

 HGBT GLW9 ENL

 Bahnhofstrasse 45

 8098 Zurich

Tel. +41-44-234 59 54

 Fax +41-44-234 87 15

 louis.eber@ubs.com

www.ubs.com

Ms. Stephanie Ciboroski

 Senior Assistant
Chief Accountant

 Division of Corporation Finance

 US Securities and Exchange Commission

 Washington, DC 20549

February 1, 2013

Re:
UBS AG Form 20-F for the fiscal year ended December 31, 2011

Forms 6-K furnished July 31, 2012 and October 30, 2012

Response dated September 10, 2012

 Dear
Ms. Ciboroski:

 We have received your letter dated January 30, 2013, outlining further comments from your office with respect to
certain accounting and other issues raised by the captioned filings of UBS AG and our responses to earlier questions raised by the Staff.

 We
are working diligently on preparing written responses to the several issues raised. We expect that this process will take more than the ten business days within which you have requested a response, because of the need to discuss the issues, and the
commitments as to future disclosure that the SEC is requesting us to make, internally among numerous senior members of management. We are in the process of finalizing our fourth quarter 2012 report, which is scheduled to be released on Tuesday,
February 5, 2013, and we will not have an opportunity to consider or incorporate any changes into that report as a result of these comments. We will, of course, consider your comments and incorporate them as appropriate into our 2012 Annual
Report on Form 20-F, which we expect to file on March 14, 2013.

 We expect to be in a position to supply our full response to your
comments by February 28, 2013.

 Please contact us if you have any concerns about this.

Very truly yours,

UBS AG

/s/ Louis Eber

/s/ Sarah Starkweather

Louis Eber

Sarah Starkweather

Group Managing Director

Director

January 30, 2013

Via E -mail
Tom Naratil
Group Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland

Re: UBS AG
Form 20-F for the Fiscal Year Ended December 31, 2011
Filed March 15, 2012
Form s 6-K filed July 31, 2012 and October 30, 2012
Response dated September 10, 2012
File No. 001-15060

Dear Mr. Naratil :

We have reviewed your filing s and your response and have the following comments.
We have limited our review to only your financial statements and related disclosures and do not
intend to expand our review to other portions of your documents.  In some of our comments, we
may ask you to provide us with information so we may better unders tand your disclosure.

Please respond to this letter within ten business days by prov iding the requested
information  or by advising us when you will provide the requested response.   Where we have
requested changes in future filings, please include a draft of your proposed disclosures that
clearly identifies new or revised disclosures.  If you do not believe our comments apply to your
facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments,  including
the draft of your proposed disclosures,  we may have  additional comments.

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

Composition of credit risk – business divisions, page 120

Wealth Management & Swiss Bank, page 120

1. We note your response to prior comment 5.  Please provide us with the proposed
disclosures that you intend to provide in your future filings to address our comment .

Tom Naratil
UBS AG
January 30, 2013
Page 2

 Consolidated Financial Statements, page 284

Note 1 – Summary of significant accounting policies, page 297

a) Significant accounting policies, page 297

10) Loans and Receivable s – Renegotiated Loans, page 301

2. We note your response to prior comments 14 and 15.  Please address the following:

 Revise your disclosure in future filings to clarify the differences between loans
renegotiated on concessionary terms and loans renegotiated on a non -
concessionary basis in terms of nonperforming classification and method of
impairment measurement.
 Tell us and revise future filings to disclose wheth er you monitor or segregate
these loans from other non -renegotiated loans within the general collective loan
assessment for purposes of measuring credit losses.  If you do not segregate these
loans from loans that were not previously renegotiated, please t ell us whether you
otherwise take into consideration the fact that these loans have been renegotiated
when measuring credit losses.

Note 16 – Goodwill and intangible assets, page 336

3. We note your response to prior comment 16, including the statement that  you do not
specifically identify the assets and liabilities that make up the excess capital.  Please
confirm that the carrying value of each cash generating unit (CGU) includes only those
assets that can be attributed directly, or allocated on a reasonabl e and consistent basis, to
each CGU and provide a robust explanation of your asset allocation process.  In this
regard, clarify whether you are able to specifically identify the assets that remain in the
Corporate Center after allocations (or conversely, w hether you are able to specifically
identify which assets have been allocated out to the CGUs).    If not, please tell us how
you concluded that you met the criteria in paragraphs 76 of IAS 36.

4. Furthermore, to the extent that you do not identify the speci fic assets and liabilities
directly attributed to each CGU, please tell us how you are able to estimate the cash flows
from such CGUs.  In your response, please address why you believe your methodology
complies with the guidance in paragraph 77 of IAS 36.

5. In your response dated September 16, 2011 you noted that one potential shortfall of the
equity attribution framework was that the attribution process will not always result in
aggregated attributed equity at the segment level being the same as equity attr ibuted to
your shareholders. You further recognized that adjustments would need to be made to
ensure that the carrying amount for purposes of the goodwill impairment test was not less

Tom Naratil
UBS AG
January 30, 2013
Page 3

 than the equity attributable to shareholders and therefore the net carry ing amount of your
assets and liabilities, which you believed was consistent with the premise and
requirements of paragraphs 76 -79 of IAS 36.  Please tell us how your current equity
attribution framework, including how it is used in determining the carryin g value of your
CGUs for purposes of goodwill impairment testing is consistent with your prior response.

Note 21 – Provisions and contingent liabilities, page 341

6. We note your response to the first bullet of prior comment 17.  You state that “the classes
of provisions are the same as the classes of contingent liabilities; however, contingent
liabilities with respect to operational risks, restructuring, loan commitments and
guarantee, and other are either not present or not deemed to merit further disclosu re in the
notes to the financial statements.”  It appears you are saying that for the above classes,
the contingent liabilities are either immaterial or do not exist.  If true, affirmatively state
that in your footnote disclosure in future filings for each  class, as this cannot be inferred
from your current disclosure.

7. We note your response to the second bullet of prior comment 17.  You appear to state that
you have not provided the disclosure required by paragraph 85(a) regarding the timing of
any outfl ows of economic benefits and the disclosures required by paragraph 85(b) for
your restructuring provision based on your determination that the information was not
material.  We note that your restructuring provision increased by CHF 393 million in
2011, wh ich represents over 7% of your pre -tax income.  Please tell us why you believe
the above disclosures are immaterial in the context of your restructuring provision.
Alternatively, please tell us how you will revise future filings to provide the above
discl osures.

8. We note your response to the second bullet of prior comment 17.  You state that you have
provided the disclosure required by paragraph 85(a) regarding the expected timing of any
outflows of economic benefits for your litigation and regulatory matters provi sion class in
Note 21 b).  We are unable to locate this disclosure.  Please direct us to the sentences in
that footnote that you believe satisfy this disclosure requirement.

9. We note your response to the second bullet of prior comment 17.  You state that  you have
provided the disclosure required by paragraph 85(b) about the uncertainties surrounding
the amount or timing of the outflow of economic benefits for your litigation and
regulatory matters provision class in Note 21 b).  We note your disclosure th at “[s]uch
cases are subject to many uncertainties…”  However, other than the uncertainty regarding
whether you will enter into a settlement, as described in the following sentence in your
disclosures, we are unable to locate any further description of the  “many uncertainties” to
which you refer.  We also note your disclosure in the following paragraph regarding the
speculative nature of your legal assessments due to unique fact patterns, novel legal
theories, early stages of adjudications, and unquantified  damages; however, this

Tom Naratil
UBS AG
January 30, 2013
Page 4

 disclosure appears to be in the context of explaining why it is impracticable to estimate
the financial effect of this class’s contingent liability.  However, the practicability
accommodation is not available for the disclosures req uired by paragraph 85(b).
Accordingly, please direct us to the sentences in that footnote that you believe satisfy this
disclosure requirement.

10. We note your response to prior comments 18 and 19.  You state that “paragraph 87 of
IAS 37 places a heavy em phasis on the nature of the items in determining which of them
can be aggregated to form a class.” You also state that you believe the nature of the
provision is the “cause giving rise to the provision” and that “when such causes are
deemed similar because  general statements about their nature and other characteristics of
the items described in [paragraphs 85 and 86 of IAS 37] provide useful information, they
are aggregated … to form class.”

However, paragraph 87 of IAS 37 does not base aggregation on an entity’s ability to
merely make similar “ general  [emphasis added ] statements” about the disclosure
requirements in paragraphs 85 and 86 of IAS 37.  It states that “it is necessary to consider
whether the nature of items is sufficiently similar for a single  [emphasis added ] statement
about them to fulfill the requirements of paragraphs  85(a) and (b) and 86(a) and (b)” of
IAS 37.

Accordingly, as previously requested in prior comment 18, please provide us with a
detailed analysis of how you determined that the individual items in the litigation and
regulatory matters class may be aggregated to form a single class. For each of the 14
matters discussed in Note 21 b), please tell us the following:

 The expected timing of cash out flows and how the expected timi ng for each item
is sufficiently similar that you are able to make a single statement for all matters
in the class.
 The uncertainties in the amount and timing of the outflow of an economic benefit.
Explain whether or not the uncertainties will increase or  decrease the timing or
the amount of the outflow.  In addition, please discuss how the uncertainties in the
amount and timing for each item are sufficiently similar that you are able to make
a single statement for all matters in the class.
 The estimated  financial effects of the contingent liabilities and how the financial
effects for each item are sufficiently similar that you are able to make a single
statement for all matters in the class.  In this regard, we note in your response to
prior comment 21 a nd 22 that it is not practicable to estimate the financial effect
of the contingent liability for some matters, but that you are able to estimate it for
other matters.  We also note from your disclosures that you are unable to estimate
the possible financi al effect due to some combination of the reasons you provide –
in other words, that there is no consistent reason that applies to all matters in this
class.  We further note in your response to prior comment 21 that you have

Tom Naratil
UBS AG
January 30, 2013
Page 5

 recognized a provision for some  of the matters in this class, but not for others.
These differences suggest that the uncertainties associated with the individual
matters in this class may not be sufficiently similar for a single statement to be
made about them.

11. We have considered you r response to prior comment 19.  You state that disaggregation of
loan repurchase demands into a separate class would not “meaningfully augment the
information presented” because you disclose the amount of the provision.  However, we
note that disaggregati on would result in additional disclosures, including a rollforward of
the changes in the provision.  Based on the information disclosed in your filing it
continues to be unclear why you have aggregated loan repurchase demands within your
litigation and reg ulatory matters provision class.  Please provide us with a comprehensive
analysis regarding the similarity of the nature, expected timing, uncertainties in amount
and timing, and estimated financial effect, as described above, to support your
conclusion.

12. We note your responses to prior comments 17, 21, 22 and 23 with respect to your
application of paragraphs 91 and 92 of IAS 37.  We will further consider this information
with the information currently requested.

Note 23 – Derivative instruments and hedge accounting, page 351

Derivatives transacted for trading purposes – Detailed example: Credit derivatives, page 354

13. We note your response to prior comment 25.  Please provide us with the proposed
disclosures that you intend to provide in your future filings to address our comment.

Additional disclosure required under SEC regulations, page 439

D – Information required by industry guide 3, page 445

Impaired and non -performing loans, page 454

14. We note your response to prior comment 26.  Please provide  us with the proposed
disclosures that you intend to provide in your future filings to address our comment.

Tom Naratil
UBS AG
January 30, 2013
Page 6

Form 6 -K filed July 31, 2012

UBS business divisions and corporate center

Corporate Center – Core Function, page 43

Results: 2Q vs. 1Q, page 44

15. We note your response to prior comment 27.  Please provide us with a more detailed
explanation of the specific refinement that was made to your methodology to determine
the change in fair value when the interest rate swaps do not have a fair value  of zero at
inception.   Specifically, tell us whether this was due to a change in how you determine
the fair value of the hedging instrument, at inception or subsequent, and clarify your old
and new methodology so we can better understand the change.   As part of your response,
provide us with background information on the hedge itself (including how many hedges
were affected), the method by which hedge ineffectiveness is assessed and measured, and
the driver for the change in methodology.   Additionally, ple ase clarify whether there was
any change in fair value methodology for any other derivative instruments, in hedging
relationships or not in hedging relationships, which did not have a fair value of zero at
inception, based on your determination to change t he methodology to determine the
change in fair value when interest rate swaps do not have a fair value of zero at
inception.    Provide sufficient details around the change that was made to the valuation of
the hedging instrument, the reason(s) that such ch anges were made, and clarification on
why only certain hedging instruments were impacted.

16. As a related matter, despite your assertion that the prior period hedge ineffectiveness
error was not material to any current or prior period, the actual nature of this error
remains unclear.  Accordingly, please provide us with a detailed response that clearly
describes the nature of the error, the periods that were impacted, and how and when it
was discovered. Please also tell us how you considered whether this err or impacted your
assessment of hedge effectiveness considering the guidance in paragraph 88 of IAS 39.

Risk management and control  – Credit risk, page 50

Exposure to selected European countries, page 54

17. We note your response to prior comment 30.  Please  tell us in more detail what
information you are currently able to track and/or provide based on your current internal
data and systems, and why specifically you are unable to disclose the information
outlined in Topic 4 of the Division of Corporate Financ e’s Disclosure Guidance:
European Sovereign Debt Exposures.   More specifically tell us whether you are able to
quantify the fair values and notional values of credit default contracts purchased and sold

Tom Naratil
UBS AG
January 30, 2013
Page 7

 by country and if so, revise your future filings to disclose such amounts. Please provide
us with the disclosure you intend to provide in future filings.

18. As a related matter, your response to prior comment 30 indicates that your tabular
disclosure on page 55 may include indexed or tranched purchased credit  derivatives.
Please revise your future filings to clearly disclose this fact, separately quantify the
amount of this protection, and disclose how the amounts are reflected in your table
amongst the different countries and counterparties.

19. In your respons e to prior comment 31 you agreed to consider enhancements to your
narrative discussion in futur

CORRESP
1
filename1.htm

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

CORRESP
1
filename1.htm

Correspondence

 UBS AG

 Postfach

CH-8098 Zurich

 Tel +41-44-234 11 11

 Deputy Group General Counsel

 Group Corporate, Transactions & Governance

 Ms. Stephanie Ciboroski

 Senior Assistant Chief Accountant

 Division of Corporation Finance

US Securities and Exchange Commission

 Washington, DC 20549

 Louis Eber

 HGBT GLW9
ENL

 Bahnhofstrasse 45

 8098
Zurich

 Tel. +41-44-234 59 54

 Fax
+41-44-234 87 15

 louis.eber@ubs.com

www.ubs.com

 August 13, 2012

Re:
UBS AG Form 20-F for the fiscal year ended December 31, 2011

 Form 6-K furnished July 31, 2012

 Dear Ms. Ciboroski:

We have received your letter dated August 10, 2012, outlining comments from your office with respect to certain accounting and other
issues raised by the captioned filings of UBS AG.

 We are working diligently on preparing written responses to the several
issues raised, including supplemental materials to be provided to the Commission. We expect that this process will take more than the ten business days within which you have requested a response, because of the need to discuss the issues, and the
commitments as to future disclosure that the SEC is requesting us to make, internally among numerous senior members of management, some of whom are away from the office on summer holidays.

We expect to be in a position to supply our full response to your comments by September 10, 2012.

Please contact us if you have any concerns about this.

 Very truly yours,

 /s/ Louis Eber

/s/ Sarah Starkweather

 Louis Eber

Sarah Starkweather

 Group Managing Director

Director

August 10, 2012

Via E -mail
Tom Naratil
Group Chief Financial Officer
UBS AG
Bahnhofstrasse 45
CH-8001 Zurich, Switzerland

Re: 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 Mr. Naratil :

We have reviewed your filing s and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing s, 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 facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filings and the information you provide in
response to these  comments, we may have  additional comme nts.

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

Operating environment and strategy, page 15

Our strategy, page 22

1. 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 -weigh ted 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 regul atory requirements, they would appear to be non -

Tom Naratil
UBS AG
August 10, 2012
Page 2

 GAAP measures .  If you are unable to support that these metrics do not meet the criteria
of a non -GAAP measure, please clearly label th ese measure s as non -GAAP in your future
filings  and provide the disclosur es required by Item 10(e) of Regulation S -K.  Refer to
General Instruction C (e) of Form 20 -F.

Financial and operating performance, page 57

Off-balance sheet, page 76

Non-consolidated securitization vehicles and collateralized debt, page 76

2. We note that the tab ular 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-consolida ted 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 .

Contractual obligations, page 79

3. 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 disclosur e 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.  To the extent th at 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 inc luded 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.   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 performa nce of certain benchmarks or variable rate debt, please provide

Tom Naratil
UBS AG
August 10, 2012
Page 3

 quantification of the amount of long -term obligations that have these types of interest
rates and thus have been excluded from the table.

Risk, treasury and capital management, page 111

Cred it risk, page 116

Composition of credit risk – UBS Group, page 118

4. 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 exp lain 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.

Composition of credit ris k – business divisions, page 120

Wealth Management & Swiss Bank, page 120

5. 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 defau lt 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 poten tial 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 ).

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

Tom Naratil
UBS AG
August 10, 2012
Page 4

 changes that were made to your ratings methodology.  In this respect, clarify whether
there was any actual improvement in credit quality and if not, the primary reas ons 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.

Investm ent Bank, page 122

Loan to BlackRock Fund, page 123

7. On page 124  you indicate  that developments through t he 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 requir ed.  Please tell us the developments you considered in  forming
your conclusion .

Impairment and default – distressed claims, page 125

8. We note that you con sider a reclassified security as an  impaired loan if the carrying value
at the balance sheet date is, on a cumulative basis, 5% or more below the carrying value
at the reclassification date adjusted for redemptions.  Please clarify this disclosure in light
of the fact that you disclose on p age 302 that impairment is recognized on reclassified
securities upon adverse revisions in cash flow estimates related to credit events.  For
example, clarify whether there could be a situation where you recognize credit loss
expense on a reclassified secu rity due to an adverse change in cash flows but you do not
consider the reclassified security to be impaired.  If so, please explain your rationale.

Market risk, page 133

9. We note your discussion on page 134 regarding the limitations of the historical
simulation VaR methodology. In light of these limitations, please tell us whether you
considered using a Monte Carlo simulation  or an alternative methodology  which
randomly generates new market factors based on a chosen distribution, instead of the
historical  simulation model that uses historical moves for each market factor replayed
exactly how they occurred.

10. We note that you continue to review the performance of your VaR implementation,
including a review of risks not included in VaR, and that you will cont inue to make
enhancements to your VaR model as needed.  Please respond to the following and expand
your disclosure in future filings as appropriate:

 Tell us the number of different VaR models that are used to determine your total
trading VaR , and discuss the drivers regarding the need to use multiple different
models.

Tom Naratil
UBS AG
August 10, 2012
Page 5

  Tell us how all of the different VaR models used are aggregated to arrive at your total
trading VaR as well as the individual market risk categories disclosed. For example,
clarify whether you simply aggregate the outputs from the different models or
whether adjustments are made, and if so, how the adjustments are determined.
 Discuss the type of risks excluded from your VaR calculation and the reasons why
such risks are exclude d.
 We note that you use the same VaR model for both internal management and
regulatory capital purposes, except for the confidence level and holding period.  Tell
us what drives the need to use different confidence levels and holding periods for
your inter nal management VaR versus your regulatory capital VaR.
 Discuss the process and validation procedures in place prior to implementing
significant model and assumption changes. For example, discuss the approval process
required, back -testing procedures perfo rmed, and periods of parallel model runs
before implementation.
 Given that your VaR models are evolving over time, tell us how you consider when
disclosure is required under Item 11(a)(4) of Form 20 -F regarding model,
assumptions and parameter changes.

11. As a related matter, we note that you present management VaR at both the Group and
Investment Bank level on page 134.  We further note your disclosure of Group Treasury
management VaR on page 152.  Please revise your disclosure in future filings to show
how the management VaR calculations for individual divisions aggregate to total Group
VaR.

Backtesting, page 135

12. Your disclosure on page 134 indicates that you use a 1 -day 99% VaR for backtesting as
required by Basel 2.5 and FINMA.  We also note that you e xperienced three backtesting
exceptions during 2011.  Please tell us whether you also perform backtesting of your
internal management VaR model (1 -day 95% VaR) and why the results of this
backtesting have not been disclosed.  Given that you have chosen to present your 1 -day
95% VaR for market risk disclosure purposes, we would expect your disclosure of
backtesting exceptions to be made on a consistent basis.   Refer to  Item 11 of Form 20 -F.

Liquidity and funding management, page 144

13. We note your disclosure  that your major sources of liquidity are channeled through
entities that are fully consolidated.  Please revise your future filings to disclose the nature
of any restrictions on the ability of your consolidated subsidiaries to transfer funds to the
parent  company in the form of cash dividends, loans or advances.

Tom Naratil
UBS AG
August 10, 2012
Page 6

 Consolidated financial statements, page 284

Notes to the consolidated financial statements, page 297

Note 1 – Summary of significant accounting policies, page 297

a) Significant accounting policies, page 297

10) Loans and Receivables – Renegotiated Loans, page 301

14. We note your accounting policy for renegotiated loans as disclosed on page 301 as well
as your disclosure on page 302 that nonperforming loans include those that have been
restru ctured on concessionary terms.  We further note your disclosure on page 125 stating
that certain renegotiated loans with new terms and conditions that met normal market
criteria for the quality of the obligor and type of loan were reclassified from impaire d to
performing in both 2011 and 2010.  Please respond to the following:

 Tell us and revise your future filings to clarify your definition of a renegotiated loan.
In this regard, clarify whether there are any instances in which a restructured or
modified  loan is not considered “renegotiated” and if so, the reasons why.
 Revise your future filings to disclose the amount of renegotiated loans at each balance
sheet date and, if material, provide a quantitative roll -forward of such loans for each
period prese nted so that a reader may understand the various drivers of changes in the
balances of those loans.
 Describe the key features of your loan modification programs, including a description
of the typical terms modified.
 Clarify your policy for classifying re negotiated loans as impaired loans at the time of
modification.  In this regard, your disclosure on page 125 indicates there are
situations in which a loan is renegotiated on terms which are not considered
concessionary and that such loans are therefore no t considered impaired.
 Clarify your policy for removing renegotiated loans initially classified as impaired
from impaired status. In this regard, you disclose that renegotiated loans continue to
be subject to impairment assessment, calculated using the loa ns original EIR.  Clarify
whether there are any situations in which a renegotiated loan is removed from
impaired status (e.g., due to performance under the modified terms for a specified
period of time) and if so, whether impairment of such loans continues  to be measured
on an individual basis or is included in your collective assessment of impairment.

15. As a related matter, we note your disclosure on page 302 that the restructuring of a
financial asset could result in the original loan being derecognized and a new loan being
recognized.  Please revise your future filings to disclose the following:

Tom Naratil
UBS AG
August 10, 2012
Page 7

  Describe the specific factors considered when determining that a new agreement is
made on substantially different terms or that the new instrument is a substant ially
different instrument.
 Clarify the types of loans that qualify for this accounting treatment (e.g., mortgages,
commercial loans, etc.).
 Clarify whether these loans remain impaired loans or whether these loans are
included within the general collecti ve pools for the purposes of measuring credit
losses and discuss how you concluded this policy was appropriate.

Note 16 – Goodwill and intangible assets, page 336

16. We note that you consider your business segments to be separate cash -generating units
(CGUs) for purposes of your goodwill impairment testing and that the carrying amount
for each segment is determined by reference to the equity attribution framework.  We
also note your disclosure on page 157 that in November 2011, your Board approved a
refinement in the methodology of equity attribution due in part to measure the return on
attributed equity (RoaE) of each busi

CORRESP
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CORRESP

 July 19, 2012

 Ms. Amy L. Starr

 Chief

 Office of Capital Markets Trends

 Division of Corporation Finance

US Securities and Exchange Commission

Washington, DC 20549

Re:

UBS AG

424 Prospectuses relating to Registration Statement on Form F-3ASR

Filed January 11, 2012

File No. 333-178960

 Dear Ms. Starr:

 Further to our conversation on Wednesday, June 27 and our letter dated May 3, 2012, we respectfully submit the following supplemental response to the comment letter dated April 12, 2012
(the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to 424 Prospectuses relating to issuances of structured notes pursuant to Registration Statement
on Form F-3ASR filed January 11, 2012 (File No. 333-178960) (the “Registration Statement”).

 On our call you asked that we
provide a narrative description of the process by which UBS values and prices a simple structured note consisting in economic terms of a zero coupon bond plus an option. Set forth below is a basic scenario describing how such a note would be priced
and offered.

 Security to be offered:

 A distributor approaches UBS with a request that UBS create a note that will pay investors a minimum of par at maturity, plus a contingent return calculated by reference to the positive return, if any, of
an identified equity index over the term of the note. The basic terms of the distributor’s request are as follows:

 Note Issuer:
UBS AG

 Maturity: Five years

Underwriting Discount: 3.0%

 Principal
Amount: $1000

 Settlement: Cash

 Underlying Index: S&P 500

 Payment at Maturity: At maturity, if the index return
is positive, each noteholder will receive principal, plus an additional payment based on the index return up to a maximum gain of XX%. If the index return is zero or negative, the investor will receive its principal amount, subject to the
creditworthiness of UBS.

 Estimated principal amount of notes to be issued: $10,000,000

 -1-

 Step 1: Determine the value of the embedded zero coupon payment obligation: The process of pricing of
a UBS 5-year zero coupon bond begins with UBS’s 5-year structured MTN funding targets. Traders use a daily funding target matrix which gives an indication of UBS’ maximum funding targets by tenor, nominal amount, denomination currency and
structured versus unstructured products. These indicative funding targets are set once a day on a floating rate basis to minimize the need to continuously update them for intraday changes in interest rates. To price or present value a zero coupon
bond, trading desks use their real-time internal curve to calculate the appropriate fixed discount rate to be applied to the principal value of the bond.

 In our example, assume at the time of pricing the 5y floating/fixed interest rate swap is quoted at 81bp and UBS has a five-year structured MTN maximum funding target of 137bps over the swap, or 2.18%
fixed. Traders will compare this to their real-time internal curves and will proceed to calculate the appropriate discount factor if their real-time internal curve is equal to or greater than the target level. Assuming this is the case in our
example, UBS calculates a net present value for a $1000 zero coupon bond issued by UBS and due in five years of $895 as of July 18, 2012.

Step 2: Establish the amount of underwriting concession: Based on market practice, UBS determines that an underwriting concession will be paid to
the distributor equal to 3.0%, or $30 per $1,000 note.

 Step 3: Establish the amount of trading profit UBS wishes to realize on the
embedded derivative: UBS determines that it wishes to target a theoretical trading profit of 0.5%, or $5.00 per note. This target represents the amount of projected trading profit that UBS reasonably expects to realize over the life of the note,
based upon market conditions prevailing at the time of pricing and UBS’s proprietary pricing models. There is no guarantee that UBS will actually realize this profit, and the actual amount of profit (or loss) that UBS realizes over the term of
the note will vary depending upon how efficiently UBS hedges its exposure as well as the trading characteristics of the underlying index (including volatility and price path), interest rate changes, credit spreads, and other economic factors.

 Step 4: Determine the amount available to finance the embedded derivative: By subtracting from the principal amount of the note the
value of (i) the zero coupon bond, (ii) the underwriting concession and (iii) the targeted theoretical trading profit, UBS is now able to determine the amount of note proceeds that are available to hedge the note’s embedded
derivative on the S&P 500:

 $1000 - $895 - $30 - $5 = $70.

 $70 of note proceeds is available to hedge the note’s embedded S&P 500 derivative position.

 Step 5: Solve for option terms: The final step in the pricing process is to determine the terms of the embedded derivative. In this case, UBS needs to determine the terms of a five-year European
style call option position on the S&P 500 with a present value of $70. In order to do this, UBS utilizes its proprietary option pricing models to price a five year call option on the S&P 500. Inputs used by the model include the current
level of the index, the fair offer volatility of the index as implied by the listed options market, and prevailing interest rates. In this case, UBS determines that an uncapped five-year European style call option on the S&P 500 has a
theoretical value of approximately $147.

 -2-

 Because the value of an uncapped option exceeds the amount available for hedging ($70), UBS can now
“fit” the option terms to match the amount available for hedging. In this case, UBS determines based upon its pricing models that capping the index return at 121% of the current level of the index will cause the option value, or implied
premium, to equal $70. By capping the return, UBS is effectively offering the investor a 100/121% call spread on the index.

 If the note is
going to be priced and sold in the same day, the cap level in this case would be fixed by UBS on the basis of the level of the underlying index and prevailing market conditions as of an agreed time (either intraday or at the close).

Because market conditions are subject to change continually, if the note is going to be marketed over a period of time, UBS will include in its
preliminary offering document a range of values for the open pricing term (in this case, the capped index return) based upon its judgment of the risk it is willing to bear during the marketing term. For a note like the one in our example, a typical
range of values might be a capped index return of not less than 119% nor greater than 123%. UBS practice requires that the range of values for the open term be sufficiently narrow to enable investors to make an informed investment decision regarding
the note (for example, UBS’s practice prohibits utilizing a range such as 100-125% for the capped index return). The open term is then fixed on the pricing date and included in the final prospectus supplement. Under no circumstance will the
open term be finalized at a level less favorable to investors than the least favorable value in the filed range (in this case, 119%).

Secondary Market Pricing: As described above and in our letter dated May 3, 2012, upon issuance of a structured note, UBS establishes a
position in its risk management system representing the estimated fair market value of the note based upon UBS’s proprietary pricing models. UBS establishes a second position in its secondary quoting system representing the aggregate value
of the underwriting discount and theoretical projected trading profit as well as the value of anticipated hedging costs over the life of the trade embedded in the offering price of the note. These two values are added to generate the note
value that appears on customer account statements as well as the basis for UBS’s secondary market bid and offer prices.

 The estimated
fair market value of the note is updated continuously based upon changes in value of the underlying reference asset or index, interest rates, currency rates, actual and assumed dividends, volatility, issuer credit quality, and the other economic
determinants of the value of the notes.

 The position in the secondary market quoting system that represents theoretical projected trading
profit and underwriting discount is amortized downward on a straight-line basis over a fixed period of time. This amortization may be accelerated in the case of larger than expected repurchases of notes.

Prior to the amortization in full of theoretical trading profit and underwriting discount, the values shown on client statements may exceed the fair
market value of the note to a third party. These values also represent the basis for UBS’s secondary market bid price. While UBS undertakes no legal obligation to make a market in the structured notes it offers, UBS’s practice is
to make a market in its securities at a bid/offer spread based upon the sum of the two positions described above. To the extent that UBS repurchases notes prior to the full amortization of theoretical trading profit and underwriting
commissions, UBS’s bid price may exceed the value that a third party would pay for a note. We are prepared to revise our disclosure to reflect these considerations.

 -3-

 Please do not hesitate to contact us if you have questions or comments or would like to discuss further the
contents of this letter.

Very truly yours,

UBS AG

By:

Gordon S. Kiesling

Executive Director

 -4-

CORRESP
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filename1.htm

Correspondence

 USB AG

 677 Washington Boulevard

 Stanford, CT 06901

Ms. Amy L. Starr

 Chief

Office of Capital Markets Trends

 Division of
Corporation Finance

 US Securities and Exchange Commission

 Washington, DC 20549

 May 3, 2012

Re:
UBS AG

424 Prospectuses relating to Registration Statement on Form F-3ASR

Filed January 11, 2012

File No. 333-178960

 Dear Ms. Starr:

 We respectfully submit the responses set forth below to the comment letter dated April 12, 2012 (the “Comment Letter”) from
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to 424 Prospectuses relating to issuances of structured notes pursuant to Registration Statement on Form F-3ASR filed January 11,
2012 (File No. 333-178960) (the “Registration Statement”). We have numbered our responses in accordance with the comments in your letter.

 Product Names

 1. We acknowledge your concern regarding note titles. UBS has not issued any
notes pursuant to the current Registration Statement using the term “principal protected” in their titles. As a general practice UBS strives not to use security titles that could be misconstrued or that present an unbalanced presentation
of a product’s benefits and risks.

 Product Pricing and Value

 2. UBS includes disclosure in its pricing supplements and product supplements alerting investors that secondary market prices for UBS’s structured notes are likely to be lower than the issue price
due to the inclusion of commissions, hedging costs and compensation in the public offering price of structured notes. The underwriting discount applicable to each note is also clearly disclosed on the cover page of each pricing supplement.

 UBS has previously considered disclosure of fair market values for its structured note products, and continues to do so. To date, UBS has not
included a quantified fair market value in its structured notes disclosure documents for a number of reasons. Because the fair market value of a structured note is constantly variable (including in the interval between pricing and preparation of a
final pricing supplement) and dependent upon several inputs (including valuations for underlying assets or indices that are themselves subject to continual fluctuations in market value), any estimate of fair market value is likely to become quickly
outdated. In addition, the use of different proprietary pricing models by issuers and market participants results in a range of fair market value estimates. We also believe that inclusion of an estimate of fair market value could be susceptible to
overreliance by investors as an ongoing representation of fair market value. Finally, because Regulation S-K and registered offering practice have to date focused on objectively verifiable facts such as the price to public and underwriting discount,
there is little to no practice or guidance available to issuers that can be applied to the estimation or establishment of “fair values” of publicly offered securities. We welcome the Commission’s guidance regarding such disclosure.

 It has not been our practice to date to attempt to estimate per note costs and expenses. The US structured
notes program incurs “platform” expenses that are incurred over time and that are not specific to individual note issuances, such as legal fees incurred with filing the base prospectus and product supplements and technology costs. Because
issuances are made on an ongoing basis, the portion of these costs allocable to any individual note issuance declines over time, making these costs difficult to allocate on a per-issuance basis. We believe that per-note costs and expenses are
immaterial.

 3. Upon issuance of a structured note, UBS establishes a position in its risk management system representing the
estimated fair market value of the note based upon UBS’s proprietary pricing models. UBS establishes a second position in its secondary quoting system representing the aggregate value of the underwriting discount and theoretical projected
trading profit as well as the value of anticipated hedging costs over the life of the trade embedded in the offering price of the note. These two values are added to generate the note value that appears on customer account statements as
well as the basis for UBS’s secondary market bid and offer prices.

 The estimated fair market value of the note is updated continuously
based upon changes in value of the underlying reference asset or index, interest rates, currency rates, volatility, issuer credit quality, and the other economic determinants of the value of the notes.

The position in the secondary market quoting system that represents theoretical projected trading profit and underwriting discount is
amortized downward on a straight-line basis over a fixed period of time. This amortization may be accelerated in the case of larger than expected repurchases of notes.

 Prior to the amortization in full of theoretical trading profit and underwriting discount, the values shown on client statements may exceed the fair market value of the note to a third party. These
values also represent the basis for UBS’s secondary market bid price. While UBS undertakes no legal obligation to make a market in the structured notes it offers, UBS’s practice is to make a market in its securities at a
bid/offer spread based upon the sum of the two positions described above. To the extent that UBS repurchases notes prior to the full amortization of theoretical trading profit and underwriting commissions, UBS’s bid price may exceed the
estimated fair market value of a structured note. We are prepared to revise our disclosure to reflect these considerations.

 Use of Proceeds and Reasons for Offerings

 4. UBS uses the proceeds of its structured notes offerings for general corporate purposes and to hedge its obligations under such notes. The proportion of issuance proceeds allocated to each of these
purposes varies from issuance to issuance. The proceeds of notes that exceed the amount required to hedge UBS’s obligations thereunder are generally utilized by UBS for general corporate purposes.

Because UBS hedges its derivatives positions on a portfolio basis, the amount of proceeds of each note that will be required to hedge can be quite
difficult to determine with certainty. To offer a simple example: UBS might issue a note requiring it to establish a long position in a certain number of shares of stock to hedge its liability. Ordinarily, a portion of the notes proceeds would be
used to purchase UBS’s hedge. However, if UBS already has a short position already in the shares in question, it will simply reduce its overall position and no funding of a new long position will be required. Because the aggregate positions
held by UBS are constantly changing, the amount of proceeds required to effect a hedge are not always known and may continue to change following execution of a transaction. As a result it is often not feasible to estimate a specific amount of
proceeds that will be used initially for hedging. UBS’s practice therefore is to disclose its general intent to use the proceeds of each offering for general corporate purposes and hedging. We do not believe that the amounts devoted to each
purpose are material to structured note investors. If required, we are able to amend our disclosure to state that offerings are made primarily to meet investor demand for structured products.

 5. As part of its discussion of funding activities, UBS has disclosed in its annual report and the notes to its annual financial statements that our structured notes programs comprise a part of UBS’s
global funding programs (see http://www.sec.gov/Archives/edgar/data/1114446/000119312512115964/d308675d20f.htm for the related Exchange Act filing). In particular, the structured notes programs are designed to respond to investor demand while, as
noted in that discussion and as shown in our notes to the financial statements, contributing at a global level to the diversification of UBS’s funding sources.

 As of December 31, 2011, the fair value of all our structured debt outstanding, globally, totaled approximately CHF 75 billion1. At the end of each of 2009, 2010 and 2011, such liabilities represented approximately 7.7%, 6.7% and 5.3%,
respectively, of UBS’s total liabilities and equity, and 12.5%, 11.3%, and 9.2%, respectively, of UBS’s total funding liabilities. Deposits, at CHF 342 billion or 42% of UBS’s total funding sources, represented UBS’s largest
source of funding as of December 31, 2011.

 Currently outstanding structured note issuances made under the Registration Statement and the
preceding registration statement on Form F-3ASR filed on January 13, 2009 total approximately $2.3 billion, representing an immaterial portion of UBS’s outstanding global structured debt issuances.

1
For general information, the spot exchange rate as of March 31, 2012 was CHF 0.90 = USD 1.

 Equity-linked notes issuances have been weighted toward autocallable structures and reverse convertibles,
with a smaller proportion of exchange-traded notes issuances, while lower interest rates have made notes with full market risk reduction features less marketable.

 Approximately 85% of the currently outstanding rates-linked structured note issuances under the Registration Statement and the Prior Registration Statement represent callable obligations, and the balance
represent obligations with a fixed maturity. Over the past three years, rates-linked note issuances have tended toward callable fixed-rate step-up notes, capped and/or floored floating rate notes and dual range accrual notes linked to short-term
floating interest rates and a published equity index.

 Registered FX-linked structured notes represent maturities ranging from three months to
three and a half years. Over the past three years, FX- and commodity linked note issuances have tended towards simple payoff structures accommodating an opportunistic investment strategy.

 Registered structured note offerings overall have tended in recent years toward more and smaller size issuances.

 Plan of Distribution

 6. UBS generally markets its structured notes to investors during a
fixed period of time, or in response to specific expressions of investor interest. In a typical structured note offering, broker-dealers, including affiliates, receive orders from their clients for a specific principal amount of notes. Those offers
are then communicated to UBS during the relevant marketing period. Prior to, or on, the trade date (pricing date), distributor broker dealers confirm their offers to UBS. On the trade date, UBS agrees to issue a number of notes equal to the
principal amount of offers to buy that distributor broker-dealers have received from their clients and communicated to UBS (and later confirmed). Those notes are purchased by the broker-dealer distributors as principal and resold to the
broker-dealer’s clients. The distributor broker-dealers generally do not purchase notes for their own account.

 With the exception of
exchange-traded notes, the vast majority of structured notes are sold at fixed prices to investors. However, in some instances notes are sold at differing prices to investors. In those instances, a preliminary offering document, such as a
preliminary pricing supplement filed as a free writing prospectus, might indicate a range of negotiated prices to be offered by dealers, other than UBS Securities LLC, to investors. For example, the range might be 97.50-100.00% of par value (the
markup to par reflecting the underwriting discount). During the marketing period for an offering with variable reoffer prices, UBS expects to receive offers from broker-dealers (on behalf of their clients) at different points in time, whereupon UBS
hedges its potential exposure under the notes at economic levels based on those offers received. This has the effect of locking in a price at a certain economic level and could operate to the end-investor’s benefit to the extent that the market
conditions at that time (as opposed to later in the offering process) allow UBS the ability to offer better pricing. Depending on the level and timing of hedging and the timing of offers received, some investors may ultimately purchase the notes at
prices that are different from other investors, to the extent UBS was able to lock in a portion of its hedge (and therefore its economic risk) at a particular level (or levels) that allow it to offer better pricing.

 The initial issuance and offer of exchange-traded notes is generally made through UBS Securities LLC, which
remarkets the notes at market prices. Following initial issuance, exchange-traded notes are marketed on a continual basis at market prices prevailing at the time of sale, at prices related to market prices or at negotiated prices. UBS occasionally
markets exchange-traded notes to retail investors through affiliated or unaffiliated broker-dealers for a fixed period of time.

 7. UBS offers
structured notes using preliminary pricing supplements — filed with the SEC as free writing prospectuses — that disclose a range for certain economic terms to be determined on a later trade (pricing) date. For example, the preliminary
pricing supplement for a note might disclose a range of 10-11% per annum as the coupon rate. The preliminary pricing supplement in that example would disclose that investors are expected to make their decision to invest based on that range and,
in particular, it would disclose that investors could ultimately receive the rate at the low end of the range. On the trade date, when the note is priced, end-investors are sold a note with a minimum annual coupon rate of 10%. The actual coupon rate
is included in a final pricing supplement filed pursuant to Rule 424(b) of the Securities Act. The size of the range is determined by a number of factors that are relevant to the pricing of the derivatives and, if applicable, the fixed income
instruments that may be imbedded in the note, such as the implied volatility of the underlying reference asset, interest rates, dividend rates, and other factors, such as the length of the marketing period. The actual terms are established based on
(i) various factors as they exist on the trade (pricing) date, including the market price and levels of implied volatility of the underlying reference asset, and interest rates, dividend rates and other factors that are relevant to the pricing
of derivatives and/or fixed income instruments, and (ii) the amount of hedging UBS conducted based on the orders received during the marketing period and the levels at which those hedges were executed.

Liquidity

 8. UBS provides standard
disclosure to structured note investors clearly indicating that investors should be willing to hold their securities to maturity and that there may be little or no secondary market for the structured notes. When applicable, UBS clearly discloses
that securities will not be listed on any securities exchange or any electronic communications network. UBS discloses its intent to make a market for the structured notes and its right to stop making markets at any time.

UBS is usually the only significant secondary market liquidity provider for structured notes that are marketed to retail investors. UBS supports the
secondary market for its structured notes by typically maintaining a continuous bid for its securities in the secondary market and repurchases structured notes from investors on most business days. In practice, UBS’s bid price for such
repurchases is based upon the estimated fair market value for such notes and unamortized theoretical projected trading profit and underwriting commissions as described in paragraph 3 above. Prior to the full amortization of theoretical trading
profit and underwriting commissions, UBS’s bid price may exceed the estimated fair market value of the note.

 Issuer Credit Risk

 9. UBS includ

CORRESP
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filename1.htm

Correspondence

UBS AG

Postfach

CH-8098 Zurich

Tel +41-44-234 11 11

www.ubs.com

 Ms. Amy L. Starr

 Chief

 Office of Capital Markets Trends

 Division of Corporation Finance

 US Securities and Exchange Commission

Washington, DC 20549

 April 18, 2012

Re:
UBS AG

 424 Prospectuses
relating to Registration Statement on Form F-3ASR

 Filed January 11, 2012

File No. 333-178960

 Dear
Ms. Starr:

 We have received your letter dated April 12, 2012, outlining comments from your office with respect to certain
disclosure issues in connection with future structured note offerings.

 We are working diligently on preparing written responses to the
several issues raised, including supplemental materials to be provided to the Commission. We expect that this process will take more than the ten business days within which you have requested a response due the need to discuss the issues with a
number of persons internally and across several business units, among numerous senior members of management, and with our Disclosure Committee.

We expect to be in a position to supply our full response to your comments by May 11, 2012.

Please contact us if you have any concerns about this.

 Very truly yours,

 Gordon S. Kiesling

Sarah Starkweather

 Executive Director

Director

April 12, 2012

Via E-mail

Sarah M. Starkweather
UBS AG
677 Washington Blvd.
Stamford, Conn ecticut  06901

Re: UBS AG
424 Prospectuses relating to Registration Statement on Form F -3ASR
Filed January 11, 2012
File No. 333-178960

Dear  Ms. Starkweather :

We are writing this letter in connection with our review of takedowns of structured notes
from shelf registration statements by financial institutions and have identified a number of areas
in which we believe there could be disclosure improvements.  Therefore, we  are issuing the
following comments  in an effort to  improve disclosures in connection with your future structured
note offerings, and in some instances, Securities Exchange Act of 1 934 reports .

Although we reviewed certain takedowns from your shelf registration statement, we are
including comments that may or may not specifically apply to your disclosures with respect to all
types of notes.  If you  disagree with a comment or  think it does not apply  to your structured note
program or certain types of notes, please explain why in your response letter.

You should also note that this letter does not address all disclosure issues that may arise
in structured note offerings.  It  is only intended to address the limited issues described in the
comments below.  If we conduct a review of your filings in the future, we may have more
specific comments.  It is your responsibility to determine the disclosures that should be provided
in your particular circumstances.

Product Names

1. The staff in the Division of Corporation Finance has previously indicated that note titles
using the term “principal protected” should also include balanced information about
limitations to the principal protec tion feature.  We believe this concern regarding
potential confusion over the titles of securities may exist for  note titles across various
product categories.  Issuers should evaluate the titles used for the ir different  types of
structured notes and should revise to  clearly describe the product in  a balanced manner

 and avoid titles that stress positive features without also identifying  limiting  or negative
features.
Product Pricing and Value

2. We note that issuers of structured notes often include disc losure, including in risk factors,
explaining that the value of the notes at issuance and/or the price that the affiliate would
pay for the notes in the secondary market, assuming no change in market conditions, will
be less than the public offering price.   In order for investors to be able to understand the
relationship of the note purchase price to its fair value (as estimated by the issuer or its
affiliate) and potential secondary market prices, we believe issuers should consider
prominently disclosing t he difference between the public offering price of the note and
the issuer or its affiliate’s estimate of the fair value of the note or discuss with us the
reasons such disclosure should not be provided.  Issuers also should consider identifying
the specif ic amounts being paid from the note proceeds for costs and expenses.

3. We have observed  that some issuers of structured notes or their affiliates will, for a
limited period of time immediately following an offering, use values on account
statements or provi de repurchase prices to customers at levels that temporarily exceed the
issuer’s or affiliate’s own estimate of the fair value of the product.   Further, we
understand that after a given period of time such  values and prices will be readjusted to
better ref lect the issuer’s or affiliate’s own estimate of the fair value of the product.   If
applicable, we ask that you disclose , including in risk factor disclosure as appropriate,
your usage of different values and prices in this manner and explain the potential  impacts
on post -offering pricing, valuation, and trading.
Use of Proceeds and Reasons for Offerings
4. Issuers often provide disclosure explaining that they will use the proceeds of a structured
note offering for general corporate purposes and may use an u nquantified portion for
hedging transactions.  Item 504 of Regulation S -K requires that  issuers disclose the
approximate amounts intended to be used for each purpose.  If the issuer does not have
specific plans for a significant portion of the proceeds of the offering, it should note the
reasons for the offering.

5. Please explain to us in your response letter with a view toward disclosure in your future
Exchange Act reports, the purpose of your structured notes program generally, and the
purposes of particu lar types of offerings or products.  Explain to us how significant
structured notes are to your overall plan of financing and liquidity position.  Please tell us
about any material trends or changes in your use of , or your experience with , structured
notes  in the past few years, including trends or changes in your reliance on structured
notes as a liquidity source.  Also tell us about trends or changes in note types and/or the

 referenced  asset classes or referenced indices.  Please include quantitative info rmation
about outstanding structured note obligations in recent periods.
Plan of Distribution

6. We have found that some issuers of structured notes disclose  that their affiliate s might
change the price and selling terms if all notes are not sold at the pub lic offering price
disclosed on the cover page. Please explain to us with a view toward disclosure, the
manner in which you conduct structured note offerings, including the forms of
underwriting involved.  Also please explain whether any notes are sold to broker -dealers,
including your affiliates, and not immediately resold to investors or are resold to
investors at differing prices.  In this situation, please explain why there may be different
prices and what type of investor may receive a “better” price.  Please explain the process
in detail.

7. Some issuers offer structured notes using a preliminary pricing supplement or term sheet
that discloses a range for certain material terms (such as a capped maximum return), with
the actual terms set within that range on a later pricing date.  If you offer  notes in this
manner, explain to us with a view toward disclosure, how the size of the range is
determined, how the actual terms are established, and when and how the actual terms are
communicated to investors.
Liquidity

8. While issuers generally disclos e in risk factors or elsewhere that the  issuer or its affiliates
may, but are not obligated to, make a secondary market in the notes that they offer, the
disclosure  should provide investors with a better understanding of the potential liquidity
or lack of liquidity of any secondary market .  In this regard, please explain to us with a
view toward disclosure, your practices and procedures with respect to providing liqu idity
in the notes you sell and how often you offer to buy back notes from investors prior to
maturity , the price paid  and how it is determined .
Issuer Credit  Risk

9. While the note terms establish the amounts due and payable on the notes, payment is
ultim ately dependent on the creditworthiness of the issuer. It is important for investors to
understand that structured notes are unsecured obligations of the issuer and any payment
on the note is subject to issuer credit risk, with no ability to pursue any ref erenced  asset
for payment .  As a result, we believe th e risk that an investor is exposed to an issuer’s
credit should be disclosed on the prospectus  supplement cover page in a clear, consistent,
and prominent manner.

 Tax Consequences

10. Item 601(b)(8) of  Regulation S -K requires the filing of  a tax opinion when  the tax
consequences are material to investors and a representation as to tax consequences is set
forth in the filing.  Refer to Staff Legal Bulletin No. 19 , which is  available on our
website , for additional details.  Given the complexity and uncertainty surrounding the tax
treatment of some types of structured notes, the tax consequences appear material to an
informed investment decision.  Please explain to us your approach to providing tax
disclosu res for the different types of notes you offer and how you determine whether such
disclosures must be based on the opinion of counsel.  If so, explain how the se opinion s
are filed as required.
Referenced Asset or Index Disclosure

11. It is our view that  an issuer may not disclaim liability or responsibility for the information
it discloses regarding the asset or index referenced by  the note because such a disclaimer
is inconsistent with the issuer’s disclosure obligations under the federal securities law s.
Issuers may, however, state that they have not undertaken any independent review or due
diligence of publicly available information regarding an unaffiliated referenced  asset or
index.  Please revise your disclosure, as appropriate, to b e consistent wi th this standard.

12. Please tell  us whether you have ever disclose d hypothetical historical price information,
for example in the case of a new index that has no historical price information.  If so,
explain to us what information the presentation provide d to investors and how it was
presented in a balanced manner.
Disclosure Format

13. We have found that disclosures in structured note offerings are usually made through
combinations of base prospectuses, various underlying prospectus supplements, and
preliminary  and final pricing supplements.  While current rules permit incorporation by
reference, it is important that it not be difficult  for investors to locate important
information or updated information.  Please explain to us what  constitutes your  disclosure
packages for structured note offerings, including the different documents you use, what
information is included in each document, and how you determine the information that
will be included in the term sheet or descriptive prospectus supplement for these
offerings.
Exhibits

14. Each time an issuer conducts a structured note offering, it may need to file certain
exhibits if it has not already done so.  For example, distribution agreements and

 instruments defining the rights of note holders may be required exhibit s.  Please explain
to us your approach to filing these and any other applicable exhibits.
Please provide us with a written response to these comments within ten business days
from the date of this letter or tell us when you will respond.  In some of our c omments, we have
specified improved disclosures  that issuers should provide.  Please explain in your response letter
how you intend to provide such disclosures in future filings .   Upon our review of your response,
we may have additional comments or questi ons.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include  the information the Securities Act of 1933 and
all applicable Securities Act rules require. Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the d isclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing s;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing s; and

 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

You may contact me or Raquel Fox at (202) 551 -3860 with any questions.

Sincerely,

/s/ Amy M. Starr

Amy M. Starr
Chief
Office of Capital Markets Trends
Division of Corporation Finance

January 27, 2012
 Via E-mail

Tom Naratil Group Chief Financial Officer UBS AG Bahnhofstrasse 45 CH-8001 Zurich, Switzerland
Re: UBS AG
Form 20-F for the Fiscal Year Ended December 31, 2010 Filed March 15, 2011
  File No. 001-15060

Dear Mr. Naratil:
 We have completed our review of your filing. We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
  /s/ Stephanie L. Hunsaker   Stephanie L. Hunsaker
Senior Assistant Chief Accountant

CORRESP
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filename1.htm

Correspondence

Via EDGAR

    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

www.ubs.com

Ms. Stephanie L. Hunsaker

Senior Assistant Chief Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington DC 20549-1090

7 November 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:

On 16 September 2011, we submitted our response 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 of UBS AG (“UBS” or
the “Company”). Our response to Comment 3 of the Comment Letter referenced information related to
the re-securitization positions reported in the Basel II Pillar 3 disclosures on page 185 of our
2010 Form 20-F.

We are writing to apprise you and the Staff of the Commission that we are re-filing our Basel II
Pillar 3 First Half 2011 Report no later than tomorrow in order to correct certain figures relating
to information as of 30 June 2011 as well as comparative figures for the period ended 31 December
2010. As stated on page 23 of the amended report, following an in-depth review of our Pillar 3
securitization disclosures, we determined that certain of our assumptions were not consistent with
industry practice and needed refining, resulting in certain corrections to amounts disclosed
previously. This review took into consideration the guidance “Industry good practice guidelines on
Pillar 3 disclosure requirements for securitization” issued by the European Banking Federation, the
Association for Financial Markets in Europe, the European Savings Banks Group and the European
Association of Public Banks and Funding Agencies. The tables including updated information are
clearly indicated as such and we have included comparative information for 31 December 2010 at the
same level of granularity as the information for 30 June 2011, rather than on an aggregated basis.
Qualitative information has been updated to the extent this was necessary to reflect the changed
principles applied, or where it was considered appropriate in order to enhance the reader’s
understanding. Those corrections have been issued today publicly in our Basel II Pillar 3 First
Half 2011 report.

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished July 26, 2011

File Number 001-15060

7 November 2011

Page 2 of 2

As a result of those corrections, one element of our response to Comment 3 should be amended as
follows (with marked changes in bold):

UBS has not originated any re-securitization SPEs in any of the periods presented;
consequently, no additional quantitative information has been provided. Approximately
CHF 1.57 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
3.35.0 billion) were acquired in the secondary market.

The corrections have no other effect on Comment 3 or other responses to the Comment Letter.

We hereby acknowledge on behalf of UBS AG that:

    •

    The Company is responsible for the adequacy and accuracy of the disclosure in the
filing.

    •

    Staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing.

    •

    The Company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

We are available to discuss this letter with you, should you so desire. If you wish to contact us,
we suggest you contact Todd Tuckner at +41 44 234 8280 (todd.tuckner@ubs.com) or Alex Brougham at
+44 207 567 7425 (alex.brougham@ubs.com).

    Very truly yours,

    UBS AG

    Tom Naratil

    Todd Tuckner

    Group Chief Financial Officer

    Head of Group Tax & Accounting Policy

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CORRESP

    αβ

    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

CORRESP
1
filename1.htm

Correspondence

UBS AG

Postfach

CH-8098 Zurich

Tel +41-44-234 11 11

www.ubs.com

Ms. Stephanie L. Hunsaker

Senior Assistant Chief Accountant

Division of Corporation Finance

US Securities and Exchange Commission

Washington, DC 20549

August 23, 2011

Re: UBS AG Form 20-F for the fiscal
year ended December 31, 2010

Form 6-K
furnished July 26, 2011

Dear Ms. Hunsaker:

We have received your letter dated
August 22, 2011, outlining comments from your office with respect to
certain accounting and other issues raised by the captioned filings of UBS AG.

We are working diligently on preparing
written responses to the several issues raised, including supplemental
materials to be provided to the Commission. We expect that this process will
take more than the ten business days within which you have requested a
response, because of the need to discuss the issues, and the commitments as to
future disclosure that the SEC is requesting us to make, internally among
numerous senior members of management, as well as our Disclosure Committee.

We expect to be in a position to supply
our full response to your comments by September 16, 2011.

Please contact us if you have any
concerns about this.

Very truly yours,

Louis Eber

Group Managing
Director

  Sarah Starkweather

Director

August 22, 2011
 Via E-mail

Tom Naratil Group Chief Financial Officer UBS AG Bahnhofstrasse 45 CH-8001 Zurich, Switzerland
Re: UBS AG
Form 20-F for the Fiscal Year Ended December 31, 2010 Filed March 15, 2011 Form 6-K Filed July 26, 2011
  File No. 001-15060

Dear Mr. Naratil:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  Where we have requested changes in  future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosu res.  If you do not believe our
comments apply to your facts and circumstances or  do not believe an amendment is appropriate,
please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.    Form 20-F for Fiscal Year Ended December 31, 2010

 Risk management and control, page 116

Impairment and default – distressed claims, page 128
 1. We note that in your retail and corporate banking busine ss in Switzerland you typically
review individual positions for impairment onl y after they have been in arrears for a

 Tom Naratil UBS AG August 22, 2011 Page 2

 certain time.  In future filings, please sp ecify the length of time (e.g., 90 days, 180 day,
etc.) for each loan category that you would wait before evaluating the loan individually
for impairment.
 Regulation and supervisi on in the U.S., page 216

2. We note your brief discussion of the Dodd-Frank Act and th e so-called Volcker rule
which may limit the ability of deposit-taki ng 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 wh ich your proprietary trading act ivities will be subject to the
Volcker rule under the U.S. Dodd-Frank Act.  In this regard, please provide your analysis
of the applicability of the Volcker rule to  your operations con ducted both within and
outside the U.S.

Financial Statements and Notes
 Note 1 – Summary of significan t accounting policies, page 273

 3)  Subsidiaries, page 273

3. We note your accounting policies related to SPE s, including for 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 al so note from review
of your Basel II Pillar 3 disclosures on  page 185 that you have done some re-
securitization tran sactions, but it is uncle ar how these transacti ons are accounted for in
your financial statements.  Pl ease tell us the following:
 Whether you consolidate any of your re-secu ritization vehicles, and provide us with
your accounting analysis to support the non-c onsolidation of any of these vehicles.
 Quantify the total assets of your re-securi tization vehicles and amount of securities
that were re-securitized in the periods presen ted.  To the extent that certain of your re-
securitization transactions are consolidated  and certain are not, please separately
quantify the amounts for each type.
 Tell us whether your clients request the re-securitization, and if so, the types of
parties that request your a ssistance in performing the re -securitization, and discuss
their role in the design of the vehicle and th e structure of the secu rities to be issued.
 Tell us whether there are situations in which you are doing re-securitizations for your
own liquidity or capital purpos es, and tell us the other parties involved that have
discretion over the design of the vehicle.
 24) Equity participation and ot her compensation plans, page 284

4. We note your disclosure that plans contai ning voluntary termination and non-compete
provisions and no vesting conditi ons are considered vested at  the grant date because no

 Tom Naratil UBS AG August 22, 2011 Page 3

 future service is requ ired.  In these cases, compensa tion expense is fully recognized on
the grant date or is recognized in a peri od prior to the grant da te if the bank can
substantiate that the award is  attributable to past servic e and the amount can be reliably
estimated.  We also note your disclosure on page 352 that compensation for all SESAP
and SESOP awards is recogni zed during the performance ye ar, 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 te ll 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.

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

 Equity and Other comprehensive income, page 289

5. We note your disclosure on page 41 where you state that you recognized an out-of-period
credit of CHF 592 million resulting from th e 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 fu rther note your disclosure on page 289 that the foreign
currency balance was adjusted by CHF 592 m illion and that it increased total other
comprehensive income by CHF 592 million a nd total comprehensive income by CHF 429
million because a loss of CHF 163 million was tr ansferred 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 id entified and separately  quantify the amount
of each misstatement by type;
 Tell us how the misstatements were identifie d.  As part of your response, please tell
us whether changes were made to your intern al controls over fi nancial reporting to
prevent these types of misstatements in the future;
 Quantify the amount of the misstatements by period; and
 Tell us whether you prepared a SAB 99 materiality analysis supporting your
conclusion that the misstatements were not ma terial.  If so, please provide us with
your analysis.
 Note 16 – Goodwill and intangible assets, page 309

6. We note your disclosure on page 309 that the carrying amount for each segment is
determined by reference to the Equity Attr ibution framework, and within the framework,
management attributes equity to the businesse s after considering thei r risk exposure, asset
size, goodwill and intangible assets.  We note that prio r to 2010, you determined the

 Tom Naratil UBS AG August 22, 2011 Page 4

 carrying value of the cash-generating units by a roll-forward of the historic carrying
amount.  Please respond to the following:
 Please tell us whether the amounts of equity  attributed to each cash-generating unit
under the Equity Attribution framework differed significantly from the amounts
previously determined for each of the cas h-generating units under the roll-forward
method.  If so, please quantity those amounts,  and tell us how you concluded that the
new amounts allocated are be tter reflective of the ca rrying amounts of the cash-
generating units.
 We note your disclosure on page 159 s howing the average amount of equity
attributed to each of the segments as co mpared to total average equity at the
consolidated level.  We also note your disc losure on page 158, that where total equity
attributed to the businesses differs from  the Group’s actual equity during a given
period, the surplus or deficit is reflected in Treasury activitie s and other corporate
items. Please clarify whether that mean s for purposes of your goodwill impairment
test you would use the equity attributed  to each segment/cash-generating unit under
the Equity Attribution framework even t hough the total would be in excess/less than
total shareholders’ equ ity.  If so, please tell us in mo re detail why you believe that is
the most appropriate way to determine the carrying value of  your cash-generating
units.   As part of your response, please address the guidance in paragraphs 76-79 of
IAS 36.

Additional disclosure required under SEC regulations, page 408

7. We note your disclosure of operating profit be fore tax per share in  the table providing
additional disclosure required under SEC regulat ions.  We did not locate the use of this
measure in other places of your document.  Gi ven that this measure is not required under
SEC regulations, and would potentially appe ar to be a non-GAAP measure, please
consider removing the measure in future fili ngs to the extent you are including it solely
because you believe it is required by SEC regul ations.  If you believe the use of this
measure is appropriate, please c onsider relocating the measure or including it as part of
your consolidated financial statements along with the disclosures required by paragraph
73 of IAS 33.

 Tom Naratil UBS AG August 22, 2011 Page 5

Form 6-K filed July 26, 2011

Risk management and control, page 38
 Exposures to sovereign of select ed industrialized European count ries rated AA and below, page
41
8. We note your disclosure of the CHF 116 million of Greek sovereign exposures as of June
30, 2011.  Please tell us how the Greek expos ures are accounted for (loans and
receivables, held for tr ading, etc.).  To the extent that any of the Greek exposures are not
held for trading or designated under the fa ir value option, please tell us whether you
recognized any credit impairment on these e xposures during the three months ended June
30, 2011.  If not, please tell us how you conc luded that an impairment event has not
occurred under paragraph 58 of  IAS 39.  Finally, please tell us whether you have written
any credit protection on Greek bonds .  If so, please tell us wh ether the notional value of
protection written is included in the CHF 116 million of Greek exposures.

Note 11 – Fair value of financial instruments, page 75

(b) Valuation information, page 78
9. We note your disclosure that during the second quarter of 2011, you corrected the own
credit effect calculation to capture the vol ume effect of foreign currency movements on
life-to-date own credit si nce initial recognition, and this co rrection contributed to an own
credit loss of CHF 77 million.  You also noted a further change due to certain
collateralized liabilities that were identified as having become insensitive to changes in
your credit spread, resulting in a CHF 37 million increase in your own credit loss.  Please
respond to the following:
 Tell us how the error was identified and describe in further detail how you new
calculation captures the volume effect of  foreign current movements on your own-
credit calculation;
 Tell us in more detail about the change made to certain collateralized liabilities and
clarify the reasons why you believe the collat eralized liabilities became insensitive to
your credit spreads.  As part of your response, please confirm that your prior
methodology was capturing the existence of collateral for all of  your liabilities,
including for these liabiliti es, (as you describe on page 331 of your 2010 Form 20-F)
when measuring the effect of your  own-credit adjustment; and
 Tell us whether you performed an assessment of the effect of these changes on your
prior period financial statements or whet her you believe such assessment is not
necessary.

 Tom Naratil UBS AG August 22, 2011 Page 6

              We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.                In responding to our comments, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Yolanda Trot ter, Staff Accountant, at (202) 551-3472 or me at (202)
551-3512 if you have any questions.
Sincerely,
  /s/ Stephanie L. Hunsaker

 Stephanie L. Hunsaker
Senior Assistant Chief Accountant

UNITED STATES
SECURITES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 18,2011
By Us. 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 Fiscal 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 September 9, 2010 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 wil provide the
requested response. If you do not believe our comments apply to your facts 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.
General
.1. It does not appear that you have fied "clean" opinions of counsel in connection
with your ongoing sales of linked notes under your shelf registration statement
(File No. 333-156695). Please advise us why "clean" opinions have not been
filed, or ifthey have been fied, where they are located.
Form 20-F for the Fiscal Year Ended December 31, 2009
General
2. We have received your response to comment 9 from our letter dated September 9,
2010 and the related supplemental correspondence dated December 31,2010.
Our review is ongoing and we may have further comments.

John Cryan
UBS AG
January 18,2011
Page 2
3. Please tell us about your contacts with Iran, Syria, Sudan and Cuba, countries
subject to U.S. economic sanctions and export controls and identified by the U.S.
State Department as state sponsors ofterrorism, since your letters to us of
November 16,2005, April 20, 2006 and September 6, 2006. In this regard, we
note the disclosure in your 20-F regarding your operations in the Middle East,
Africa and Latin America, and the disclosure in your 20-F for fiscal 2007 that you
decided to exit commercial and client business dealings with countries including
Iran and Sudan. Please discuss the nature and extent of your contacts with these
countries, whether direct or through affiliates, partners, or other indirect
arrangements.
4. Please discuss the materiality of your contacts with Iran, Cuba, Syria or Sudan
described in response to the foregoing comment and whether those contacts
constitute a material investment risk for your security holders. You should
address materiality in quantitative terms, including the approximate dollar
amounts of any associated revenues, assets, and liabilities for the last three fiscal
years and subsequent interim period. Also, address materiality in terms of
qualitative factors that a reasonable investor would deem important in making an
investment decision, including the potential impact of corporate activities upon a
company's reputation and share value. As you may be aware, various state and
municipal governments, universities, and other investors have proposed or
adopted divestment or similar initiatives regarding investment in companies that
do business with U.S.-designated state sponsors of terrorism. Your materiality
analysis should address the potential impact of the investor sentiment evidenced
by such actions directed toward companies that have operations associated with
Iran, Cuba,S yria and Sudan.
5. Please also discuss the potential for reputational harm from your relationships
with third parties. For instance, we note from 2007 and 2008 news articles that
you have provided advisory or investment banking services to PetroChina, which
has contacts with Iran, Syria, Sudan and Cuba, and which acknowledges on both
its website and in its most recent 20-F the risk of adverse investor reaction to
PetroChina because ofthe operations of its parent, China National Petroleum
Corporation, in all four countries, as well as its own operations relating to those
countries. In addition, we note from 2008 news articles that you purchased a
large block of stock in Sinopec Shanghai Petrochemical, which acknowledges in
its most recent 20-F negative publicity and divestment of its stock because of its
parent companies' Sinopec Corp. and Sinopec Group operations in Iran, Syria,
Sudan and Cuba. Please discuss the significance to you of these types of
relationships, and the potential for harm to your reputation and share value to
suffer as a result of your relationships with such companies.

John Cryan
UBS AG
January 18,2011
Page 3
Exhibits, page 21
Exhibit 4.1
6. We note your response to our prior comment 1. Please address why you believe
you are not required to fie the Deferred Prosecution Agreement in its entirety in
light of your obligations as a reporting company. In the alternative, please amend
your Form 20-F to fie the agreement in its entirety or submit an application for
confidential treatment pursuant to Exchange Act Rule 24b-2.
Closing Comments
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

June 15, 2011
 Via E-mail

Tom Naratil Group Chief Financial Officer UBS AG Bahnhofstrasse 45 CH-8001 Zurich, Switzerland
Re: UBS AG
Form 20-F for the Fiscal Year Ended December 31, 2009 Filed March 15, 2010 File No. 001-15060

Dear Mr. Naratil:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
 Sincerely,

 /s/ Michael Seaman

Michael Seaman Special Counsel

CORRESP
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Correspondence

    UBS AG
Postfach
CH-8098 Zürich
Tel. +41-44-234 11 11

www.ubs.com

Via EDGAR and messenger

Mr. Michael Seaman

Special Counsel

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

June 6, 2011

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. §200.83

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 Mr. Seaman:

We respectfully submit the responses set forth below to the comment letter dated May 20, 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,
2009 (the “2009 Form 20-F”), (b) the first quarter 2010 report on Form 6-K (the “Q1 2010 Form
6-K”), and (c) the second quarter 2010 report on Form 6-K (the “Q2 2010 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. As you requested, we have included supplemental
information where applicable.

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,
requested in the comment.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    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

    Page 2 of 3

We understand that a number of U.S. states and local governments have proposed or adopted
legislation requiring divestment from, or reporting of interests in, companies that do business in
certain countries. We further understand that this legislation is designed to restrict support of
business in sanctioned countries to enhance the effect of existing sanctions measures against the
current regimes of the countries in question. We believe that our implementation of our internal
sanctions policy is consistent with these goals.

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 Regulations) 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.

UBS operates in compliance with US sanctions law and does not maintain active client relationships
with Iranian parties or other sanctioned persons in violation of sanctions restrictions imposed by
the United States, including the Iran Financial Sanctions Regulations. UBS’ internal sanctions
policy imposes broad prohibitions against business activity with or involving Iran. UBS’ provision
of products and services to the US government is not affected by the implementation of CISADA given
our comprehensive global sanctions policy.

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.

We hereby confirm that if and when Exhibit E to the Deferred Prosecution Agreement is unsealed by
the United States District Court for the Southern District of Florida, we will refile the Deferred
Prosecution Agreement in its entirety as an exhibit to UBS’s 2009 Annual Report on Form 20-F.

UBS AG requests that this letter be treated as confidential and that we receive timely notification
and be afforded an opportunity to object if any request for it is received under the Freedom of
Information Act or any other law, based on the competitive damage that would arise from its
release.

We are available to discuss this letter with you, should you so wish. If you wish to contact us, we
suggest you contact Louis Eber at 011-41-44-234-5954 or John Cusack at 011-44-20790-15772.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    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

    Page 3 of 3

    Very truly yours,

    UBS AG

    /s/ Louis Eber

    /s/ John-Paul Cusack

    Louis Eber

    John-Paul Cusack

    Group Managing Director

    Managing Director

    Deputy General Counsel

    Head of AML Compliance

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

CORRESP
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Correspondence

αβ

    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.

CORRESP
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corresp

    UBS AG

    Postfach

    CH-8098 Zürich

    Tel. +41-44-234 11 11

    www.ubs.com

Via EDGAR and messenger

Mr. Michael Seaman

Special Counsel

Division of Corporation Finance

United States Securities and Exchange

Commission

100 F Street, N.E.

Washington, D.C. 20549

February 18, 2011

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. §200.83

UBS AG

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

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

Dear Mr. Seaman:

We respectfully submit the responses set forth below to the comment letter dated January 18, 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,
2009 (the “2009 Form 20-F”), (b) the first quarter 2010 report on Form 6-K (the “Q1 2010 Form
6-K”), and (c) the second quarter 2010 report on Form 6-K (the “Q2 2010 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. As you requested, we have included supplemental
information where applicable.

Reference is also made to an earlier comment letter from the Staff dated September 9, 2010 (the
“September Comment Letter”) with respect to the filings noted above. UBS responded to the
September Comment Letter on October 7, 2010. In a subsequent telephone call with the Staff related
to Comment 15 in the September Comment Letter, UBS undertook to include in our Annual Report on
Form 20-F for the year ended December 31, 2010, enhanced disclosure of our exposures to sovereign
debt issued by countries that have suffered market dislocation. We hereby confirm our intention to
include such enhanced disclosure.

General

1. It does not appear that you have filed “clean” opinions of counsel in connection with
your ongoing sales of linked notes under your shelf registration statement (File No. 333-
156695). Please advise us why “clean” opinions have not been filed, or if they have been
filed, where they are located.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 2 of 8

The validity opinions of Sullivan & Cromwell LLP (as to New York law) and Homburger AG (as to Swiss
law) filed as exhibits 5.1 and 5.3, respectively, to the referenced registration statement
contained conditions that reflected the fact that the opinions were written at a time when the
registration statement had not yet been filed or become effective, and the specific authorization
of any securities to be issued under the registration statement had not yet occurred. We believed,
based on advice of counsel and on our own experience with previous Form F-3 filings, that these
conditions were typical in opinions filed as Exhibit 5 to shelf registration statements, and we
continue to believe that our filing is consistent with long-standing and current market practice.

In order to file completely clean opinions, we would need to file separate opinions under both U.S.
and Swiss law at the time of each issuance under the registration statement. We do not believe
that it is standard market practice to do so, although we acknowledge that some less-frequent
issuers do so. In 2010, we completed about 230 separate takedowns under the registration
statement. We would ask the Staff to consider the substantial time and cost burdens involved in
preparing and filing both U.S. and Swiss opinions on a nearly daily basis for a frequent issuer
like UBS. Further, we believe that the constant stream of Forms 6-K put on the record will make it
much more difficult for investors to watch for filings containing truly important information about
UBS.

We understand that Sullivan & Cromwell and others are discussing with the Staff the best way to
address the Staff’s concern on this point, on UBS’s behalf and on behalf of other registrants. We
would ask that we be permitted to await the outcome of those discussions before agreeing to a
specific course of action.

2. We have received your response to comment 9 from our letter dated September 9, 2010 and
the related supplemental correspondence dated December 31, 2010. Our review is ongoing and
we may have further comments.

We await the outcome of completion of the Staff’s review of this item.

3. Please tell us about your contacts with Iran, Syria, Sudan and Cuba, countries subject to
U.S. economic sanctions and export controls and identified by the U.S. State Department as
state sponsors of terrorism, since your letters to us of November 16, 2005, April 20, 2006
and September 6, 2006. In this regard, we note the disclosure in your 20-F regarding your
operations in the Middle East, Africa and Latin America, and the disclosure in your 20-F for
fiscal 2007 that you decided to exit commercial and client business dealings with countries
including Iran and Sudan. Please discuss the nature and extent of your contact with these
countries, whether direct or through affiliates, partners, or other indirect arrangements.

UBS has no subsidiary or affiliate, employees or other physical presence in any of the Subject
Countries. *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 3 of 8

UBS is a globally active financial institution and recognizes its obligations towards various
stakeholders, laws and regulations. During 2005, after conducting a careful evaluation of business
and risks, UBS adopted a global sanctions policy and decided to end business dealings on a
group-wide, global basis with a limited number of countries, including Iran, Cuba, Sudan, Myanmar,
North Korea, and — to a lesser extent — Syria (save for a limited number of permitted transactions
such as those for the United Nations and a limited number of certain other
international/humanitarian organizations). Our commitment to this policy is serious and forms part
of the corporate culture that starts at the top of the organization and runs all the way through
its operations. This decision required us to exit client relationships with individuals (except
Syrian nationals) and institutional clients domiciled in these countries, and no new or further
business has been undertaken since we began to implement our policy decision in 2005.
Implementation of this policy, including exiting relationships and implementing global systems and
controls, began in 2005 and was largely complete by the end of 2006.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

4. Please discuss the materiality of your contacts with Iran, Cuba, Syria or Sudan
described in response to the foregoing comment and whether those contacts constitute a
material risk for your security holders. You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets and
liabilities for the last three fiscal years and subsequent interim period. Also, address
materiality in terms of qualitative factors that a reasonable investor would deem important
in making an investment decision, including the potential impact of corporate activities
upon a company’s reputation and share value. As you may be aware, various state and
municipal governments, universities and other investors have proposed or adopted divestment
or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism. Your materiality analysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Iran, Cuba, Syria and Sudan.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

We understand that a number of U.S. states and local governments have proposed or adopted
legislation requiring divestment from, or reporting of interests in, companies that do business in
certain countries. We further understand that this legislation is designed to restrict support of
business in sanctioned countries to enhance the effect of existing sanctions measures against the
current regimes of the countries in question. We believe that our implementation of our internal
sanctions policy is consistent with these goals.

5. Please also discuss the potential for reputational harm from your relationships with
third parties. For instance, we note from 2007 and 2008 news articles that you have provided
advisory or investment banking services to PetroChina, which has contacts with Iran, Syria,
Sudan and Cuba, and which acknowledges on both its website and in its most recent 20-F the
risk of adverse investor reaction to PetroChina because of the operations of its parent,
China National Petroleum Corporation, in all four countries, as well as its own operations
relating to those countries. In addition, we note from 2008 news articles that you
purchased a large block of Sinopec Shanghai PetroChemical, which acknowledges in its most
recent 20-F negative publicity and divestment of its stock because of its parent companies’
Sinopec Corp. and Sinopec Group operations in Iran, Syria, Sudan and Cuba. Please discuss
the significance to you of these types of relationships, and the potential for harm to your
reputation and share value to suffer as a result of your relationships with these companies.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 4 of 8

UBS continues to apply its internal sanctions policy to protect the firm’s reputation and ensure
compliance with the economic sanctions laws of the jurisdictions in which it does business. In
addition to recognizing applicable local sanctions restrictions, the policy applies a set of
sanctions restrictions consistent with the sanctions restrictions imposed by the United Nations,
European Union, United States and Switzerland. These business restrictions apply to any entity
that is UBS controlled.

While the existence of particular sanctions does not mean that all transactions involving parties
having connections to or with a particular country are prohibited, UBS is keenly aware of the
reputational risks that can accompany business activities connected to sanctioned parties. It
therefore employs risk-based, internal procedures to prevent its products and services from being
used to facilitate business with sanctioned parties. These internal restrictions may result in
UBS’s refusal of business, even if permissible under applicable law. UBS’s sanctions controls
continue to evolve, and emphasis on indirect sanctions risk has increased.

UBS assesses the reputational risk associated with business activity, including investment banking
activity, on a case-by-base basis. Decisions are highly dependent on circumstances and facts
available at a particular time. A decision to conduct business with a client in the circumstances
existent on one date does not mean that UBS would proceed with a similar transaction presented at a
later date. In reviewing a potential business proposal, UBS considers a variety of factors and
informational sources, taking particular note of those companies predominantly engaged in
sanctioned countries. These internal controls were employed in UBS’s careful consideration of its
participation in the 2007-2008 Petrochina A-share IPO listing on the Shanghai stock market. UBS
conducted a thorough review of available facts and proceeded after satisfying itself that its
services in furtherance of the IPO were supporting domestic projects in China, and not projects in
sanctioned countries. While UBS gave particular consideration to the fact that Petrochina’s
parent, CNPC, had activities in Sudan, it also observed that Petrochina was a separate corporation
with listings on the New York and Hong Kong stock exchanges that neither had operations in Sudan
nor derived any revenues from Sudan.

The reputational risk connected with an activity can depend in part on the regulations and guidance
provided by the office that administers the U.S. sanctions programs, the U.S. Department of the
Treasury’s Office of Foreign Assets Control. UBS has taken note of written OFAC guidance, made
available by industry groups, which outlines the circumstances under which U.S. persons’ minority
ownership of companies doing business with sanctioned countries is, in fact, permissible.

Sinopec Shanghai Petrochemical has not been sanctioned by the U.S. government. UBS has no control
or strategic participation in Sinopec Shanghai Petrochemical, which is ultimately majority-owned
and controlled by the Chinese government. UBS’s holdings of shares in Sinopec Shanghai
Petrochemical constitute a small percentage of issued shares and a small portion of UBS holdings.
*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 *** UBS does not view this level of holdings as
material or potentially material to investors.

Exhibits, page 21

Exhibit 4.1

6. We note your response to our prior comment 1. Please address why you believe you are
not required to file the Deferred Prosecution Agreement in its entirety in light of
your obligations as a reporting company. In the alternative, please amend your Form 20-F to
file the agreement in its entirety or submit an application for confidential treatment
pursuant to Exchange Act Rule 24b-2.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 5 of 8

When we filed our 2009 Annual Report on Form 20-F in March 2010, we believed that filing the
Deferred Prosecution Agreement (DPA) as an exhibit was required because the agreement itself was
material to UBS, and both (i) was to be performed in whole or in part on or after the date of the
filing, and (ii) was entered into not more than two years before the filing date. The DPA has five
exhibits — i.e., Exhibits A-E — four of which were included in our filing. We did not include
Exhibit E in our filing because Exhibit E was filed under seal by the Department of Justice and
remains under seal pursuant to an order (the “Seal Order”) issued in February 2009 by the United
States District Court for the Southern District of Florida in United States of America v. UBS AG,
Case No. 09-60033-CR, February 18, 2009 (S.D. FL.) in connection with that Court’s approval of the
DPA at that time. Absent the Seal Order, Exhibit E would have been included in the filing. In our
filing, we clearly disclosed its absence, and indicated in abbreviated form the reason.

By way of background, the DPA resolved a lengthy investigation by the Department of Justice, Tax
Division (“DOJ”) of UBS’s U.S. cross-border business. The DPA was presented to and approved by the
District Court on February 18, 2009. In connection with the execution of the DPA, DOJ filed a
one-count criminal information (the “Information”) charging UBS with conspiracy to defraud the IRS
through the operation of the U.S. cross-border business through which Swiss-based private bankers
allegedly assisted U.S. clients in evading their U.S. income tax obligations. The DPA had a
minimum term of 18 months, and contained a number of obligations that UBS had to fulfill in that
time, including completing its previously announced exit from its U.S. cross-border business. If
during that 18-month term, or any permitted extension, UBS fulfilled all of i

CORRESP
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filename1.htm

Correspondence

UBS AG

Postfach

CH-8098 Zurich

Tel +41-44-234 11 11

Deputy Group General Counsel

Group Corporate, Transactions &
 Governance

Louis Eber

HGBT GLW9 ENL

Bahnhofstrasse 45

8098 Zurich

Tel. +41-44-234 59 54

Fax +41-44-234 87 15

Louis.eber@ubs.com

Mr. Michael Seaman

Special Counsel

Division of Corporation Finance

US Securities and Exchange Commission

Washington, DC 20549

Via EDGAR and fax to 703.813.6967

January 24, 2011

    Re:

    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 No. 001-15060

Dear Mr. Seaman:

We have received your letter dated January 18, 2011, outlining comments from your office with respect to certain issues
raised by the captioned filings of UBS AG.

We are working diligently on preparing written responses to the several issues raised, including supplemental materials
to be provided to the Commission. We expect that this process will take more than the ten business days within which
you have requested a response, because of the need to gather information from numerous sources at our operations in
different regions, and the fact that some of the people involved in gathering and preparing the statistical
information, as well as members of senior management who will need to review the material, are also involved in
preparing the year-end financial statements that will be included in our 2010 Form 20-F filing.

We expect to be in a position to supply our full response to your comments by February 18, 2011.

Please contact us if you have any concerns about this.

Very truly yours,

    /s/ Louis Eber

    /s/ Sarah M. Starkweather

    Louis Eber

    Sarah M. Starkweather

    Group Managing Director

    Director

CORRESP
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filename1.htm

Correspondence

    ab

    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

    Via EDGAR and messenger

    Fax +41-44-234 7361

    todd.tuckner@ubs.com

    Ms. Kathryn McHale

    www.ubs.com

    Assistant Chief Accountant

    Division of Corporation Finance

    United States Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

October 7, 2010

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:

We respectfully submit the responses set forth below to the comment letter dated September 9, 2010
(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,
2009 (the “2009 Form 20-F”), (b) the first quarter 2010 report on Form 6-K (the “Q1 2010 Form
6-K”), and (c) the second quarter 2010 report on Form 6-K (the “Q2 2010 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. As you requested, we have included supplemental
information where applicable.

Comment 1

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

Exhibits, page 21

Exhibit 4.1

We note that Exhibit 4.1 to your form 20-F refers to an Exhibit E, a letter agreement between UBS
and the U.S. government, which does not appear to have been provided. Please be aware that when you
file an agreement pursuant to Instruction 4 to Exhibits on Form 20-F, you are required to file the
entire agreement, including all exhibits, schedules and appendices. Please amend your Form 20-F to
file the full and complete Deferred Prosecution Agreement, including any exhibits, schedules and
appendices which are included in such agreement.

The Deferred Prosecution Agreement (DPA), as filed as Exhibit 4.1 to UBS’s 2009 Form 20-F, was full
and complete in all respects except that it omitted Exhibit E thereto. Exhibit E to the DPA
specifies the characteristics of the U.S. person account information that was delivered by UBS to
the US Department of Justice (DOJ) pursuant to paragraph 9 of the DPA and an order of the Swiss
Financial Market Supervisory Authority (FINMA).

    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

    October 7, 2010

    Page 2 of 18

Exhibit E was omitted from the Form 20-F filing because, at the request of the DOJ, that exhibit
was filed under seal pursuant to a court order, which remained in full force and effect at the time
the Form 20-F was filed and remains so today. DOJ applied for and obtained the court’s approval to
seal this document. Without court approval, UBS would not be able to provide the Exhibit to the SEC
or file it as an exhibit to the Form 20-F.

UBS filed the DPA because it is a material agreement to UBS as described in Instruction 4(a) of the
Instructions as to Exhibits in Form 20-F. However, UBS believes that the information contained in
Exhibit E is not material in any respect to the financial condition or financial statements of UBS.

Comment 2

Risk and treasury management

Composition of credit risk – UBS Group, page 119

We refer to your “Credit exposure by business division” table on page 119 which provides a
breakdown of your banking and trading product exposures before and after impairments, credit
valuation adjustments and specific hedges. Please revise your future filings to more clearly define
how your gross credit exposure was determined for each product. For example, the gross credit
exposure for loans in Wealth Management & Swiss Bank, Wealth Management Americas and Other business
divisions appears to equal the carrying value of loans in each of these divisions. However, for
your Investment Bank division you show that the gross credit exposure for loan products is CHF 25.4
million while the carrying value of loans in this division is CHF 90.7 million as of 31 December
2009.

We agree to more clearly define in our future filings how our gross credit exposure was determined
for each product. However, we would like to highlight that in our Annual Report 2009, page 115, we
included a specific section explaining that we have different measures of risk exposure depending
on the purposes for which exposures are calculated: financial accounting under IFRS, determination
of our regulatory capital, or our internal management of the firm.

With respect to the disclosure of our Investment Bank loan exposures, you correctly identify that
there is a difference between the balance sheet carrying value of loans (as reported under IFRS)
and our internal risk view of these exposures. This is primarily driven by adjustments to exclude
margin that we post to counterparties against negative replacement values, prime brokerage cash
accounts and securities that are classified as loans and receivables. We would like to highlight
that on page 122, we included the table “Investment Bank: net banking products exposure to
corporates and other non-banks.” The Investment Bank’s banking products portfolio is defined as
loans and contingent claims and irrevocable commitments. The table specifically identifies the
adjustments required to derive our internal risk view of loans and contingent claims and
irrevocable commitments from the equivalent balance sheet reported exposures. However, we agree to
more clearly define in our future filings the linkage between the various credit exposure tables
and our descriptions of the different exposure measures used.

    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

    October 7, 2010

    Page 3 of 18

Comment 3

Composition of credit risk – business divisions, page 120

Investment Bank, page 122

Based on your “Allowances and provisions for credit losses” table on page 126, it appears that the
majority of your loans are held within the Wealth Management & Swiss Bank business division.
However, the Investment Bank also holds a significant portion of your loans (approximately 30% as
of December 2009). In an effort to provide greater transparency and granularity to your
disclosures, please revise your future filings to disclose the composition of the Investment Bank
lending portfolio in a level of detail similar to that disclosed for Wealth Management & Swiss Bank
on page 121.

The “Allowances and provisions for credit losses” table on page 126 shows our balance sheet
reported exposures for loans under IFRS. As discussed in 2 above, our IFRS reported exposures for
Investment Bank loans differ from our internal risk view. In the table “Investment Bank: net
banking products exposure to corporates and other non-banks”, we specifically identify the
adjustments required to derive our internal risk view of loans and contingent claims and
irrevocable commitments from the equivalent balance sheet reported exposures. Furthermore in the
tables on page 123, we provide granular information on our Investment Bank net banking product
exposures by internal rating and loss-given-default (LGD) buckets, by industry sector and also by
geographical region. These disclosures are similar to the level of granularity provided on our
Wealth Management and Swiss Bank banking product and lending portfolios. However, we agree to more
clearly define in our future filings the linkage between the various credit exposure tables and our
descriptions of the different exposure measures used.

Comment 4

Impaired loans, allowances and provisions, page 125

We note that your disclosure in Note 1(a)(11) that for purposes of measuring impairment on
specifically identified impaired loans, you include amounts that may result from restructuring or
liquidation of the collateral in your estimate of expected future cash flows. We also note,
however, that as of 31 December 2009 your allocated allowances represent only 56.3% of your
impaired lending portfolio after considering the estimated liquidation proceeds of the underlying
collateral. Please provide us with more clarity around how estimated liquidation proceeds from
collateralized financial assets are factored into your impairment measurements and explain how you
considered the guidance in paragraph AG84 of IAS 39 when developing your calculation of the present
value of estimated future cash flows.

As detailed in Note 1(a)(11) on page 267 of our Annual Report 2009, UBS applies the principles of
IAS 39 to evaluate individual credit exposures based on the borrower’s character, overall financial
condition, resources and payment record; the prospects for support from any financially responsible
guarantors; and the realizable value of any collateral if applicable. In keeping with the guidance
in paragraph AG84 of IAS 39, the estimated recoverable amount is the present value, using the
loan’s original effective interest rate, of expected future cash flows, including amounts that may
result from restructuring or the liquidation of collateral.

The table “Allowances and provisions for credit losses” on page 126 of our Annual Report 2009
provides information on our lending portfolio, allowances for credit losses, the estimated
liquidation proceeds of collateral and various ratios by business division. You correctly
identified that at 31 December 2009 our allocated allowances represented 56.3% of our impaired
lending portfolio after
considering the estimated liquidation proceeds of collateral. By business division, the comparable
ratio for Wealth Management & Swiss Bank was approximately 77%, whereas for the Investment Bank the
ratio was approximately 49%. The relatively low ratio for the Investment Bank is explained by two
legacy restructured leveraged finance positions with a total carrying value of CHF 1.1 billion for
which the cumulative allowances for credit losses had been written off. The remaining loan balances
on these positions were assessed as largely recoverable and therefore had de minimis remaining
allowances for credit losses at 31 December 2009. Excluding these positions, the Investment Bank’s
allocated allowances would have represented 68% of its impaired loan portfolio. In addition, one of
the legacy restructured leveraged finance loans with a carrying value of CHF 0.9 billion at 31
December 2009, was subsequently sold early in third quarter 2010 at no additional cost to the firm
(i.e. the sale proceeds realized in the market were commensurate with the carrying value).

    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

    October 7, 2010

    Page 4 of 18

Comment 5

Notes to the consolidated financial statements

Note 1(a)(11) – Allowance and provisions for credit losses, page 267

Please revise your future filings to more comprehensively disclose your process for collectively
measuring impairment on those loans that have not been specifically identified as impaired.
Consider the following in your revised disclosures:

    •

    Disclose how loans with similar risk characteristics are grouped to be evaluated for loan
collectability (such as loan type, past-due status, and risk);

    •

    Disclose how historical loss rates are determined and what factors are considered when
establishing appropriate time frames over which you evaluate loss experience; and

    •

    Describe any qualitative factors (e.g., industry, geographical, economic, and political
factors) that have affected loss rates or other loss measurements.

We agree to provide more comprehensive disclosure in our future filings on our process for
collectively measuring impairment on those loans that have not been specifically identified as
impaired and to consider the various factors you have identified.

Comment 6

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

We note that securities purchased and sold are generally treated as collateralized financing
transactions. You also disclose that securities delivered under repurchase agreements are not
derecognized from the balance sheet unless the risks and rewards of ownership are relinquished.
Please address the following:

    •

    Tell us and revise your future filings to clearly disclose whether you have derecognized
any securities delivered in your repurchase agreements.

    •

    If you have, provide us the specific facts and circumstances related to these transactions
and provide us your accounting analysis that supports your treatment. Also, provide us with
and revise your future filings to quantify the amount derecognized at each balance sheet date,
the average amount derecognized for the periods presented and discuss how you calculated the
average amount.

We do not derecognize securities delivered in repurchase transactions. Under IFRS, our repurchase
transactions are accounted for as collateralized financing transactions (i.e. UBS does not
relinquish the risk and rewards of ownership of the securities transferred). In future filings, we
will revise our policy description to eliminate the term generally.

    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

    October 7, 2010

    Page 5 of 18

Comment 7

Note 11 – Trading portfolio, page 294

We note that you present the debt instruments in both your trading and available-for-sale
investment portfolios in three categories based on the issuers of such securities (e.g., government
and government agencies, banks, corporates and others). In an effort to provide greater
transparency and granularity to your disclosure, please consider disaggregating these categories
into additional classes of financial instruments (for example, by product type). Provide us with
your proposed revised disclosure for future filings, if applicable.

In Note 11 Trading portfolio and Note 13 Financial investments available-for-sale of our financial
statements 2010, we will present carrying amounts for debt instruments held for trading and
available-for-sale by counterparty type (government/ government agencies, banks, corporates and
other) and product type. The product type information we intend to provide will consider
materiality aspects and is expected to present carrying values for bonds (split by government
bills/bonds and corporate bonds, including bonds issued by financial institutions), asset-backed
securities (split by mortgage-backed securities and other), and loans, complemented by fair value
hierarchy information (levels 1 to 3).

Comment 8

Note 13 – Financial Investments available-for-sale, page 296

We note that you present the total net unrealized gains/(losses) for your available-for-sale
investment portfolio as an aggregate (net) amount. Such aggregate presentation does not necessarily
provide a clear indication of your exposure to impairment risk on those securities that are
currently in an unrealized loss position. In the interest of transparency and consistent with the
guidance in paragraph 31 of IFRS 7, please revise your future filings to provide disclosures that
will enable a reader to more clearly assess the extent of your impairment risk exposure on your
available-for-sale investment portfolio. For example, consider revising your disclosure to
separately present gross unrealized losses and gross unrealized gains on investment securities.
Please also consider classifying the gross unrealized losses by duration (e.g., less than 12 months
and greater tha

CORRESP
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filename1.htm

Correspondence

UBS AG

Postfach

CH-8098 Zurich

Tel +41-44-234 11 11

www.ubs.com

Ms. Kathryn McHale

Attorney Advisor

Division of Corporation Finance

US Securities and Exchange Commission

Washington, DC 20549

Via fax to 703.813.6967

September 10, 2010

    Re:

    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

Dear Ms. McHale:

We have received your letter dated September 9, 2010, outlining comments from your office with respect to certain
accounting and other issues raised by the captioned filings of UBS AG.

We are working diligently on preparing written responses to the several issues raised, including supplemental materials
to be provided to the Commission. We expect that this process will take more than the ten business days within which
you have requested a response, because of the need to discuss the issues, and the commitments as to future disclosure
that the SEC is requesting us to make, internally among numerous senior members of management, as well as our
Disclosure Committee.

We expect to be in a position to supply our full response to your comments by ten business days beyond your requested
time frame, which will be October 7, 2010.

Please contact us if you have any concerns about this.

Very truly yours,

/s/ John Cryan

/s/ Todd Tuckner

John Cryan

Todd Tuckner

Group Chief Financial Officer

Head of Group Tax & Accounting Policy

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

September 9, 2010
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 Fiscal 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 filings and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within te n 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 facts and circumstan ces, 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

 Exhibits, page 21

 Exhibit 4.1

 1. We note that Exhibit 4.1 to your Form 20- F refers to an Exhibit E, a letter
agreement between UBS and the U.S. Government, which does not appear to have been provided.  Please be aware that  when you file an agreement pursuant to
Instruction 4 to Exhibits on Form 20- F, you are required to file the entire
agreement, including all exhibits, schedul es and appendices.  Please amend your

John Cryan
UBS AG September 9, 2010 Page 2

Form 20-F to file the full and complete Deferred Prosecution Agreement,
including any exhibits, sc hedules and appendices whic h are included in such
agreement.
 Risk and treasury management

 Composition of credit risk – UBS Group, page 119

 2. We refer to your “Credit exposure by bus iness division” table on page 119 which
provides a breakdown of your banking and trading product exposures before and after impairments, credit valuation adjust ments and specific hedges.  Please revise
your future filings to more clearly de fine how your gross credit exposure was
determined for each product.  For example, the gross credit exposure for loans in Wealth Management & Swiss Bank, Wea lth Management Americas and Other
business divisions appears to equal the car rying value of loans in each of these
divisions.  However, for your Investment Bank division you show that the gross credit exposure for loan products is CH F 25.4 million while the carrying value of
loans in this division is CHF 90.7 million as of 31 December 2009.
 Composition of credit risk – business divisions, page 120

 Investment Bank, page 122

 3. Based on your “Allowances and provisions for credit losses” table on page 126, it appears that the majority of your loans ar e held within the Wealth Management &
Swiss Bank business division.  However,  the Investment Bank also holds a
significant portion of your loans (approximately 30% as of 31 December 2009).  In an effort to provide greater transpar ency and granularity to your disclosures,
please revise your future filings to disclose the composition of the Investment Bank lending portfolio in a level of detail  similar to that disclosed for Wealth
Management & Swiss Bank on page 121.
 Impaired loans, allowances and provisions, page 125

 4. We note your disclosure in Note 1(a) (11) that for purposes of measuring
impairment on specifically identified im paired loans, you include amounts that
may result from restructuring or liquidati on of the collateral in your estimate of
expected future cash flows.  We also note, however, that as of 31 December 2009
your allocated allowances represent only 56.3% of your impaired lending
portfolio after consideri ng the estimated liquidation proceeds of the underlying
collateral.  Please provide us with more clarity around how estimated liquidation proceeds from collateralized financial asse ts are factored into your impairment
measurements and explain how you consid ered the guidance in paragraph AG84
of IAS 39 when developing your calculation of the present value of estimated

John Cryan
UBS AG September 9, 2010 Page 3

future cash flows.

Notes to the consolidated financial statements

 Note 1(a)(11) – Allowance and pr ovision for credit losses, page 267

 5. Please revise your future filings to more  comprehensively disclose your process
for collectively measuring impairment on those loans that have not been
specifically identified as impaired.  Consider the following in your revised
disclosures:

• Disclose how loans with similar risk characteristics are grouped to be
evaluated for loan collectability (such as loan type, past-due status, and risk);
• Disclose how historical loss rates ar e determined and what factors are
considered when establishing appr opriate time frames over which you
evaluate loss experience; and
• Describe any qualitative factors (e .g., industry, geographical, economic, and
political factors) that have affected loss rates or other loss measurements.

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

 6. We note that securities purchased and sold are generally  treated as collateralized
financing transactions.  You also di sclose that securities delivered under
repurchase agreements are not derecognized  from the balance sheet unless the
risks and rewards of ownership are relinqu ished.  Please address the following:

• Tell us and revise your future filings to clearly disclose whether you have
derecognized any securities delivered  in your repurchase agreements.
• If you have, provide us the specific fact s and circumstances related to these
transactions and provide us your acco unting analysis that supports your
treatment.  Also, provide us with and re vise your future filings to quantify the
amount derecognized at each balanc e sheet date, the average amount
derecognized for the periods presen ted and discuss how  you calculated the
average amount.
 Note 11 – Trading portfolio, page 294

 7. We note that you present the debt instru ments in both your trading and available-
for-sale investment portfolios in three categories based on the issuers of such
securities (e.g., government and government agencies, banks, corporates and others).  In an effort to provide grea ter transparency and granularity to your
disclosure, please consider disaggregating these categories into additional classes
of financial instruments (for example, by product type).  Provide us with your

John Cryan
UBS AG September 9, 2010 Page 4

proposed revised disclosure for fu ture filings, if applicable.

Note 13 – Financial Investments available-for-sale, page 296

 8. We note that you present the total net unreal ized gains/(losses) for your available-
for-sale investment portfolio as an ag gregate (net) amount.  Such aggregate
presentation does not necessarily provid e a clear indication of your exposure to
impairment risk on those securities that  are currently in an unrealized loss
position.  In the interest of  transparency and consistent with the guidance in
paragraph 31 of IFRS 7, please revise your future filings to provide disclosures that will enable a reader to more clearly assess the extent of your impairment risk exposure on your available-for-sale investment portfolio.  For example, consider revising your disclosure to separately present gross unrealized losses and gross
unrealized gains on investment securities.  Please also consid er classifying the
gross unrealized losses by duration (e.g., le ss than 12 months and greater than 12
months) or by security type.
 Note 26 – Capital increases and mand atory convertible notes, page 318

 9. We note your disclosures regarding your mandatorily convertible notes (MCNs)
issued in March and December 2008.   Please respond to the following:

• Tell us how you concluded that upon i ssuance of the MCNs in March and
December the conversion option should be separated into more than one component whereby a portion of the c onversion option (presumably related to
the obligation to deliver a fixed number of shares) is accounted for as an
embedded equity instrument, and a portion of the conversion option (presumably related to the obligation to deliver a variable number of shares
worth a fixed amount between the minimum and maximum number of shares that could have potentially been issued upon conversion) is accounted for as a derivative liability.
• As it relates to the March 2008 issuance, tell us the nature of the adjustments
to the conversion prices that resulted in  the MCNs being treated as an equity
instrument upon the adjustment.
 Note 27 – Fair value of financial instruments, page 318

 10. We note that you provide high level disc losure of your valuation principles
beginning on page 318 and more specific information about certain significant
product categories and related valuation t echniques and models beginning on page
325.  Given the multitude of financial instruments carried at fair value and the varying degrees of complexity associated  with valuing such instruments, please
revise your future filings to  disclose the valuation methods and assumptions used
in determining the fair value for each class  of financial instrument pursuant to the

John Cryan
UBS AG September 9, 2010 Page 5

guidance in paragraph 27 of IFRS 7. Consideration should also be given to
providing this disclosure on a more gr anular level (e.g., by product type).

Note 29(b) – Measurement categories of fina ncial assets and financial liabilities –

Reclassification of financial assets, page 332
 11. We note that during 2008 and the first quarter of 2009 you reclassified certain
debt financial assets from your held-for-t rading portfolio to loans and receivables
mainly due to illiquid markets for these instruments.  Please tell us whether such instruments were reclassified pursuant to  paragraph 50B or 50D of IAS 39 and
explain how you determined you met the requirements of such guidance.  For example, explain how you determined that  securities reclassified as loans and
receivables would have met the definition of  a loan or receivable if they had not
been required to be classified as he ld for trading at in itial recognition.
 12. As a related matter, please tell us and re vise your future filings to reconcile your
reclassified assets disclose d in the table on page 332 to footnote (2) to the table on
page 292.  Please also ensure that your disclosure concerning your auction rate
securities holdings (both those reclassified  and initially classified as loans) is
consistent throughout your filing.  It is unclear how the auction rate securities
figures on pages 141, 292, and 332 re late to one another.

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

13. It does not appear that you have provided all of the information regarding outstanding loans granted to members of  the BoD and GEB as required by Item
7.B.2 of Form 20-F, including, for example, the nature of the loan and the transaction in which it was incurred and the interest rate on the loan.  Please provide us with this information and conf irm that you will revi se future filings
accordingly.
 Form 6-K furnished May 4, 2010

 Notes to the financial statements

 Note 27 – Fair value of financial instruments, page 64

 14. We note your disclosure on page 65 re garding the changes made in the
discounting methods used to account for the impact of your own credit on the valuation of your financial li abilities designated at fair value.  We also note that
you revised your methodology for estimati ng debit valuation adjustments to
incorporate your own risk in the valua tion of derivative lia bilities during 2009
based on your disclosure on page 319 of your Form 20-F.  Given the multiple

John Cryan
UBS AG September 9, 2010 Page 6

changes to the methods used to incorpor ate your own credit risk in your valuation
of derivatives and financial liabilities designated at fair  value, please provide the
following:

• Provide us with a comprehensive de scription of your current valuation
methodology for these liabilities;
• Clearly describe the valuation methods a nd assumptions used to estimate fair
value and provide more clarity around the changes made to such methods and
assumptions during recent periods;
• Tell us how you considered whether your pr ior valuations of such derivatives
and financial liabilities designated at fair value reflected  the appropriate
amount of own credit risk; and
• Provide us with a sample computation which illustrates the calculation of a
debit valuation adjustment.
 Form 6-K furnished July 27, 2010

 15. We note your disclosure on page 28 that your emerging markets revenues
declined, due at least in pa rt to ongoing market concerns , particularly in Europe,
about the impact of sovereign debt a nd the European Union response.  Given
these market concerns, and your significant exposure to  sovereign counterparties,
please tell us, and in future filings e nhance your disclosure, to provide further
quantitative exposure, by country, to a ny country whose credit rating is AA or
below.  As part of your response, plea se address which financial statement line
item these exposures are included.
 16. We note your disclosure on page 69 th at you are involved in a number of
litigations in which parties allege bre aches of representations and warranties on
various whole loans and certain other assets transferred in securitization
transactions.  Please tell us whether y ou have recognized any provision related to
these alleged breaches, and if not, please te ll us which criteria in paragraph 14 of
IAS 37 is (are) not met.  To the exte nt you do not believe you are able to
determine a range of possible outcomes, pl ease tell us why and discuss the steps
you have taken to try to determine a range.  As part of your response, please provide additional information regarding the types of counterparties alleging the
breaches, additional background on the dollar amount of claims made to date, and
the nature of any discussions held with the counterparties with  respect to these
allegations.
 Closing Comments

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exch ange Act rules require.  Since the company

John Cryan
UBS AG September 9, 2010 Page 7

and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.

In responding to our comments, please provide a written statement from the
company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.  You may contact Angela Connell at (202) 551-3426 or Hugh West, Accounting
Branch Chief, at (202) 551-3872 if you ha ve questions regarding comments on the
financial statements and related matters.  Please contact Justin Dobbie at (202) 551-3469
or me at (202) 551-3464 with any other questions.

Sincerely,

Kathryn McHale Attorney Advisor

Mail Stop 3010
          January 28, 2010
Mr. John Cryan Group Chief Financial Officer UBS AG  Bahnhofstrasse 45 CH-8001 Zurich, Switzerland

Re: UBS AG
 Form 20-F for the fiscal year ended December 31, 2008
 Filed March 11, 2009
File No. 001-15060

Dear Mr. Cryan:
We have completed our review of your Fo rm 10-K and do not, at this time, have
any further comments.

Sincerely,

Jessica Barberich
       Assistant Chief Accountant

CORRESP
1
filename1.htm

Correspondence

    UBS AG
Postfach
CH-8098
Zürich
Tel. +41-44-234 11 11

    www.ubs.com

Via EDGAR and fax

Ms. Jessica Barberich

Assistant Chief Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

January 7, 2010

UBS AG

Form 20-F for the fiscal year ended December 31, 2008

Filed March 11, 2009

File Number 001-15060

Dear Ms. Barberich:

We are pleased to submit our responses to the additional comments dated December 2, 2009 (the
“Additional Comments”) from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) relating to the annual report on Form 20-F for the fiscal year ended December 31,
2008 (the “2008 Form 20-F”) of UBS AG (“UBS” or the “Company”). For your convenience, we have set
out the text of each comment contained in the Additional Comments, followed by our response.

Comment 1

Form 20-F for the year ended December 31, 2008

Sale of assets to a third-party fund controlled by the Swiss National Bank (SNB), page 358

We have reviewed your response to our prior comment 12, and note that you believe the assets sold
to the fund owned and controlled by the Swiss National Bank met the criteria for derecognition in
paragraphs AG42-AG44 of IAS 39, since the call option, put option and contingent share issue are
not directly linked to the underlying assets. We note, however, that the call option, put option
and contingent share issue are directly linked to either the fund or the SNB’s loan to the fund
which is secured by the assets of the fund and that the fund is a special purpose vehicle that was
set up for the sole purpose of acquiring these assets from your company; it appears that although
the form of the related agreements is not directly linked to the underlying assets, the substance
of the agreements does link them to the assets. Please explain. Furthermore as stated in paragraph
AG43 of IAS 39, “The critical question is what the transferee is able to do in practice, not what
contractual rights the transferee has concerning what it can do with the transferred asset or what
contractual prohibitions exist.” Given the lack of an active market for the transferred assets,
please discuss further how you determined that the transferee would, in practice, be able to
dispose of the transferred assets to a third party without attaching similar options or ‘strings’
to the transfer. Also, you stated in your response that other peers of your company sold similar assets to specialized investment funds in 2008; please
tell us the conditions of these sales, if known.

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2008
Filed March 11, 2009
File Number
001-15060
January 7, 2010
Page 2 of 4

This response should be read in conjunction with our October 23, 2009 response (the Response) to
comment 12 of the Commission’s comment letter dated September 23, 2009. As noted in the Response,
UBS must consider whether we have retained control of the transferred financial assets (refer to
Step 8 of the Response). The call option, put option and contingent share issue do not provide a
basis to impose constraints on the Fund’s sales of assets to unrelated third parties nor
necessitate that the Fund write similar types of arrangements in connection with such sales. They
neither require delivery of the transferred financial assets back to UBS in the event of their
exercise nor expose UBS to subsequent changes in the fair value of the transferred assets once sold
by the Fund. Further information on each instrument follows:

Call option:

The call option gives UBS the right to purchase Fund equity. As per the Response, it
provides UBS with a mechanism to participate in the upside returns realized from the Fund’s
activities. Further, we note that the Fund’s returns are not simply a function of the
transferred assets but include Fund expenses and financing costs, for example, interest
expense incurred on the loan provided by the SNB to the Fund (at a rate of LIBOR plus 250
basis points). The call option does not restrain the Fund from selling the transferred
assets in any way and does not require the Fund to demand that third party purchasers enter
into similar arrangements and does not provide UBS with the right to require the Fund to
deliver transferred assets back to it.

Paragraphs AG42, AG43(b)(ii) and AG51(h) all discuss call options that require the
transferred assets to be delivered to the transferor upon exercise and thus those cases do
not apply to our set of facts. Another key difference between our call option and the call
options discussed in those paragraphs is that such options would continue to expose the
holder to the risks and rewards of the transferred asset after it had been subsequently sold
by the transferee to a third party (that is why they create ‘strings’ as discussed in
AG43(b)(ii)). Under the structure of the transaction between UBS and the Fund, in contrast,
UBS loses even its indirect, partial exposure to the risks and rewards of the assets upon
their sale by the Fund to a third party. This is because the call option relates, as
explained, to the equity of the Fund and not to the underlying assets. Neither the call
option nor any other aspect of the contractual relationship between the parties imposes
restrictions on sale that would require the Fund to attach similar options or strings on
sales to third parties.

Put option:

In the event of a change in control, the put option gives the SNB the right but not the
obligation to request that UBS purchase the SNB’s loan to the fund and 100 percent of its
equity. This option provides the SNB the opportunity to disengage itself from the Fund in
the event that UBS experiences a change in control event. Like the call option, it does not
relate to the underlying assets themselves. That is, the assets transferred by UBS to the
Fund can be freely sold by the Fund because the Fund is under no obligation to return sold
assets to UBS in the event of a change in control; additionally, notwithstanding the put
option, UBS ceases to be even indirectly, partially exposed to the risks and rewards of the
underlying assets upon their sale by the Fund to third parties. Neither the put option nor
any other aspect of the contractual relationship between the parties imposes any
restrictions on the sale of transferred assets that would require the Fund to attach similar
options or strings on sales to third parties.

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2008
Filed March 11, 2009
File Number 001-15060
January 7, 2010
Page 3 of 4

Contingent share issue:

The contingent share issue will be made in the event that the SNB incurs a loss on its loan
to the Fund. The contingent share issue does not require physical delivery of the
transferred assets back to UBS. Further, transferred assets once sold by the Fund do not
impact the value of the loan or the value of the contingent share issue. The contingent
share issue likewise does not impose restrictions on sale that would require the Fund to
attach similar options or strings on sales to third parties.

In conclusion, the call option, put option and contingent share issue do not impose restrictions on
subsequent sales by the Fund either contractually or in practice. As noted above, the Fund has
control over the assets because it has (i) the unilateral ability to dispose of its assets
independently of the actions of UBS or any other party, and (ii) the ability to sell its assets
into the market free of any conditions. The call option does give UBS the right to acquire the
Fund’s equity after the Fund has fully repaid the SNB loan but the composition of the assets that
the Fund holds at such time is not subject to any restrictions and may for example consist entirely
of cash. The Fund’s unrestricted freedom to sell its assets, and its practical ability to do so,
is further evidenced by the fact that the Fund has sold, without imposing restrictions or strings,
individual transferred assets from a broad range of asset classes during 2009 for proceeds of
approximately USD 1.4 billion. Also, the Fund is able to risk-manage its assets independent of
UBS’s interests, including, but not limited to, the purchase of hedges, and may do this in a manner
that might prejudice UBS’s interests under the call option.

In addition to the above comments, we note that the SNB consolidates the Fund in its financial
statements and has recognized the Fund’s assets on its balance sheet. In our view, this further
supports our assessment that de-recognition of the assets transferred to the Fund is the correct
accounting for this transaction.

In respect of sales of similar assets to specialized investment funds made by peers of UBS in 2008,
we do not know the precise terms and conditions at which these sales were executed.

Comment 2

Form 6-K filed November 3, 2009

Note 18 Goodwill Impairment, page 80

We note your disclosures regarding goodwill in your Form 20-F for the year ended December 31, 2008
(on page 247 of your Annual Report and in Note 16) and your Quarterly Report 3Q09 (in Note 18)
which is included in your Form 6-K filed November 3, 2009. If the recoverable amount of any
cash-generating unit is not substantially in excess of its carrying value, please tell us (as of
December 31, 2008 and September 30, 2009) and in future filings disclose the percentage by which
the recoverable amount exceeded the carrying value as of the date of the most recent test. Please
also consider expanding your disclosure of the key assumptions used in your valuation models and
provide us with your proposed disclosure.

At December 31, 2008 and at September 30, 2009 the fair value of each of the cash-generating units
that carried goodwill exceeded their carrying value by more than 30%. We believe that a fair value
of 1.3 times the carrying value meets the criteria of “substantially in excess of its carrying
value”. In future filings, we will provide the disclosures required by IAS 36 paragraph 134(f) if a
reasonably possible change in a key assumption would cause the fair value of one of our cash
generating units to fall below its carrying value.

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2008
Filed March 11, 2009
File Number
001-15060
January 7, 2010
Page 4 of 4

In future filings, we will expand our disclosures of key assumptions to provide information on the
long-term growth rates assumed in our cash flow projections beyond the five years covered by our
business plan and the assumed return on equity. The discount rates for each of the cash generating units
disclosed in our filings reflect the cost of equity. We expect to provide this additional
information in a tabular format complemented by text disclosure where necessary to provide context.

We believe that our responses above appropriately address your comments. Should you have further
comments or wish to discuss these matters in greater detail, please contact William Widdowson, Head
Group Controlling and Accounting, at 011-41-1-234-5565, or Dieter Meyer, Head of Group Accounting
Policy & Valuation, at 011-41-1-236-8257.

    UBS AG

    /s/ John Cryan

    /s/ William Widdowson

    John Cryan

    William Widdowson

    Group Chief Financial Officer

    Head Group Controlling & Accounting

Mail Stop 3010
          December 2, 2009
Mr. John Cryan Group Chief Financial Officer UBS AG  Bahnhofstrasse 45 CH-8001 Zurich, Switzerland

Re: UBS AG
 Form 20-F for the fiscal year ended December 31, 2008
 Filed March 11, 2009
File No. 001-15060

Dear Mr. Cryan:
We have reviewed your response letter  dated October 23, 2009, and have the
following additional comments.  Please be as detailed as necessary in your explanations.  In our comments, we may ask you to provide  us with information so we may better
understand your disclosure.  After reviewing th is information, we may or may not raise
additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 20-F for the year ended December 31, 2008

 Sale of assets to a third-party fund contro lled by the Swiss National Bank (SNB), page
358
 1. We have reviewed your response to ou r prior comment 12, and note that you
believe the assets sold to the fund ow ned and controlled by the Swiss National
Bank met the criteria for derecogniti on in paragraphs AG42-AG44 of IAS 39,
since the call option, put op tion and contingent share is sue are not directly linked
to the underlying assets.  We note, howev er, that the call option, put option and
contingent share issue are di rectly linked to either the fund or the SNB’s loan to
the fund which is secured by the assets of  the fund and that the fund is a special
purpose vehicle that was set up for the sole  purpose of acquiring these assets from
your company; it appears that although the form of the related agreements is not

Mr. John Cryan
UBS AG December 2, 2009 Page 2
directly linked to the underlying assets, the substance of the agreements does link
them to the assets.  Please explain.  Fu rthermore as stated in paragraph AG43 of
IAS 39, “The critical question is what the transferee is ab le to do in practice, not
what contractual rights the transferee has concerning what it can do with the
transferred asset or what c ontractual prohibitions exist. ”  Given the lack of an
active market for the transferred as sets, please discuss further how you
determined that the transferee would, in practice, be able to dispose of  the
transferred assets to a thir d party without attaching sim ilar options or ‘strings’ to
the transfer.  Also, you stat ed in your response that ot her peers of your company
sold similar assets to specialized inve stment funds in 2008; please tell us the
conditions of these sales, if known.
 Form 6-K filed November 3, 2009

 Note 18 Goodwill Impairment, page 80

 2. We note your disclosures regarding goodw ill in your Form 20-F for the year
ended December 31, 2008 (on page 247 of your Annual Report and in Note 16)
and your Quarterly Report 3Q09 (in Note 18)  which is included in your Form 6-K
filed November 3, 2009.  If the recoverabl e amount of any cash-generating unit is
not substantially in excess of  its carrying value, please tell us (as of December 31,
2008 and September 30, 2009) and in future filings disclose the percentage by
which the recoverable amount exceeded the carrying value as of  the date of the
most recent test.  Please also consider  expanding your disclosure of the key
assumptions used in your valuation mode ls and provide us with your proposed
disclosure.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
response that keys your responses to our  comments and provides any requested
information.  Detailed cover le tters greatly facilitate our re view.  Please understand that
we may have additional comments after re viewing your responses to our comments.
 If you have any questions, you may contact  Eric McPhee at (202) 551-3693 or me
at (202) 551-3782.

Sincerely,    Jessica Barberich
Assistant Chief Accountant

CORRESP
1
filename1.htm

corresp

Via EDGAR and fax

Ms. Jessica Barberich

    Assistant Chief Accountant

    Division of Corporation Finance

    United States Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

UBS AG

Postfach

CH-8098 Zürich

Tel. +41-44-234 11 11

www.ubs.com

October 23, 2009

UBS AG

Form 20-F for the fiscal year ended December 31, 2008

Filed March 11, 2009

File Number 001-15060

Dear Ms. Barberich:

We are pleased to submit our responses to the comment letter dated September 23, 2009 (the “Comment
Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
relating to the annual report on Form 20-F for the fiscal year ended December 31, 2008 (the “2008
Form 20-F”) 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. As you requested, we have
included supplemental information where applicable.

Comment 1

Off-Balance Sheet, page 47

Support to non-consolidated investment funds, page 50

You disclose that in 2008, as a result of the financial markets crisis which caused declining asset
values, market illiquidity and de-leveraging by investors, you supported several non-consolidated
investment funds that you manage in your wealth and asset management businesses. Please tell us if
you reassessed your treatment of these funds for consolidation as a result of the additional
support and provide us with the results of your reassessments, if applicable.

Yes, UBS reassessed the consolidation status of funds to which it provided support. Such
reassessments took into account the specific facts and circumstances at the time support was
provided, legal considerations, the nature of the support, the risk and reward profile after the
support, the ability of UBS to control the fund as well as the probability of recurrence of such
support. As a result of those reassessments, one fund was consolidated. As for the other funds,
UBS has not absorbed or committed to absorb the majority of the risks and therefore has not
consolidated them.

Comment 2

Credit Risk, page 134

Past due but not impaired loans, page 145

UBS AG

Form 20-F for the fiscal year ended

December 31, 2008

Filed March 11, 2009

File Number 001-15060

October 23, 2009

Page 2 of 17

We note that past due but not impaired loans that are 61-90 days old and over 90 days old increased
significantly from year to year. Please discuss this trend and tell us in more detail how you
determined that these loans were not impaired.

As background information, UBS distinguishes between loans that are “past due” and “impaired.” A
loan is considered to be past due when a significant contractual payment has been missed. UBS
considers a loan as impaired if it is probable that it will not fully recover all contractual
payments due under the loan as a result of the borrower’s inability to meet its obligations.

Past due loans are identified and assessed by credit monitoring teams for impairment. That
assessment includes an evaluation of a debtor’s ability to repay the loan, including an evaluation
of collateral that can be liquidated by UBS to settle outstanding loan amounts. If based on that
assessment, UBS concludes that the loan is impaired, a valuation allowance is recognized. Loans in
the 61—90 days and over-90 days categories were assessed for impairment according to that
procedure and were not assessed as impaired at 31 December 2008.

The year-over-year increases in the 61—90 days and over-90 days categories were driven by
macro-economic factors, namely, the worsening credit environment in 2008 following the prolonged
deterioration in global financial markets and recessionary pressures in the international and the
Swiss domestic economies. The increase in the 61-90 days category primarily related to the lombard
lending portfolio (loans secured by marketable securities). The increase in the over-90 days
category largely related to three corporate loans from the Swiss domestic lending portfolio, which
accounted for more than 70 percent of the increase.

Approximately 85 percent of the loans in the 61-90 and over-90 days categories were subsequently
repaid in full or became performing loans in the first six months of 2009. As of June 30, 2009,
approximately 10 percent of the loans were still considered past due and continue to be monitored
but have not been assessed as impaired. The remaining 5 percent were reclassified as impaired based
on events occurring after December 31, 2008.

Comment 3

Note 23 Derivative instruments and hedge accounting, page 312

We note your disclosure regarding your credit derivatives in Note 23. Concerning your involvement

as a seller of credit derivatives, please tell us, and disclose the following information in future

filings for your credit default swaps and total rate of return swaps:

    •

    Discuss the types of credit events or circumstances that would require you to perform under
the credit derivatives and the current status of the payment/performance risk of the credit
derivatives;

    •

    Discuss the nature of (1) any recourse provisions that would enable you to recover from
third parties any of the amounts paid under the credit derivatives and (2) any assets held
either as collateral or by third parties that, upon the occurrence of any specified triggering
event or condition under the credit derivative, you can obtain and liquidate to recover all or
a portion of the amounts paid under the credit derivative. Please indicate, if estimable, the
approximate extent to which the proceeds from liquidation of those assets would be expected to
cover the maximum potential amount of future payments under the credit derivative. In your
estimate of possible recoveries, please tell us the effect of purchased credit protection with
identical underlying(s).

Types of Credit Events

Substantially all of UBS’s credit default swaps (“CDS”) and total rate of return swaps (“TRS”) are
traded under an International Swap and Derivatives Association (“ISDA”) master trading agreement
(“MTA”) between UBS and its counterparty. UBS’s CDS trades are also documented using industry
standard forms of documentation published by ISDA or equivalent terms documented in a bespoke
(i.e., tailored) agreement. Those forms and agreements use standardized terms that form the basis
for market

UBS AG

Form 20-F for the fiscal year ended

December 31, 2008

Filed March 11, 2009

File Number 001-15060

October 23, 2009

Page 3 of 17

conventions related to the types of credit events that would trigger performance (i.e., payment)
under a CDS.

The types of credit events that would require UBS to perform under a CDS contract are subject to
agreement between the parties at the time of the transaction, but nearly all transactions are
traded using the credit events that are applicable under certain market conventions based on the
type of reference entity to which the transaction relates. For North American and European
corporate reference entities, the applicable credit events by market convention are “bankruptcy,”
“failure to pay” and, in some cases, “restructuring.” For other entities, including most emerging
market reference entities, the applicable credit events by market convention also include
“obligation acceleration” and “repudiation/moratorium” in addition to “bankruptcy,” “failure to
pay” and “restructuring” (although “bankruptcy” is generally not included for sovereign reference
entities).

Payment/Performance Risk

UBS is an active dealer in fixed income instruments and CDS and related products with respect to a
large number of issuers. As a general matter, risk to the relevant issuers arising from both fixed
income instruments and CDS and related products are reviewed and risk-managed on a net exposure
basis (i.e. taking into account all exposures to a particular issuer arising from both fixed income
instruments and CDS and related products).

The substantial majority of UBS’s derivatives trading (including CDS and TRS) is on a
collateralized basis. This means that credit exposures arising from derivatives activities with
counterparties are either closed out in full or reduced to nominal levels on a regular basis
(typically daily) by the use of collateral. Derivatives trading with counterparties with higher
credit ratings (for example, a large bank or broker-dealer) is typically under an ISDA MTA and
credit exposures to those counterparties from CDS, together with exposures from other OTC
derivatives, are netted and included in the calculation of the collateral required to be posted
under the credit support annex of the ISDA MTA. Trading with lower rated counterparties (for
example, hedge funds) would also generally require an initial margin to be posted by the
counterparty.

UBS therefore receives collateral from or posts collateral to its counterparties based on its open
net receivable or net payable from its OTC derivatives activities. Under the terms of the ISDA MTA
and like forms used by UBS, that collateral (which generally takes the form of cash or highly
liquid fixed income securities, e.g., securities issued by the US Treasury) is available to cover
any amounts due under those derivative contracts. Consequently, counterparty credit risk
associated with CDS (and other OTC derivatives including TRS) is generally low as the collateral
received by UBS (when it has a net receivable) or posted by UBS to a counterparty (when UBS has a
net payable) generally would be expected to minimize such risk.

As of June 30, 2009, approximately 98 percent of UBS’s total gross notional CDS (i.e., the
aggregate of bought and sold notional) was traded on a collateralized basis. The tables below show
a more detailed breakdown of the proportion of UBS’s CDS trading portfolio that is collateralized
and uncollateralized by total notional exposure and positive and negative replacement values (i.e.,
derivative assets and derivative liabilities with positive and negative fair values, respectively).
CDS trading with monoline insurers was largely uncollateralized which is reflected in the
differences in positive replacement values between the tables. UBS has previously disclosed its
exposures and losses related to monoline insurers as a risk concentration. The related quantitative
disclosures for those CDS as of December 31, 2008, and June 30, 2009, can be found, respectively,
on page 125 of 2008 Form 20-F and page 44 of our 2Q09 quarterly report.

CDS Portfolio Inc. Monolines (Split by Collateralised and Uncollateralised CDS Providers)

    % of Postive

    % of Negative

    Counteparty Type

    % of Total Notional

    Replacement Value

    Replacement Value

    Collateralised

    98
    %

    84
    %

    99
    %

    Uncollateralised

    2
    %

    16
    %

    1
    %

UBS AG

Form 20-F for the fiscal year ended

December 31, 2008

Filed March 11, 2009

File Number 001-15060

October 23, 2009

Page 4 of 17

CDS Portfolio Exc. Monolines (Split by Collateralised and Uncollateralised CDS Providers)

    % of Postive

    % of Negative

    Counteparty Type

    % of Total Notional

    Replacement Value

    Replacement Value

    Collateralised

    99
    %

    94
    %

    99
    %

    Uncollateralised

    1
    %

    6
    %

    1
    %

Settlement risk (including payment risk) of CDS has been mitigated to some extent by the
development of a market wide credit event auction process which has resulted in a widespread shift
to the cash settlement of CDS following a credit event on a reference entity. Almost 75 percent of
settlements on CDS that UBS had traded in 2008 and first half of 2009 were settled by a credit
event auction. UBS has not experienced any significant losses from failed settlements on CDS
contracts in 2008 or the first six months of 2009.

Recourse Provisions

As noted previously, UBS uses standardized agreements and forms as the basis for its CDS and TRS
contracts. Those agreements and forms do not contain recourse provisions that would enable UBS to
recover from third parties any amounts paid out by UBS (i.e., this is the case if a credit event
occurs and UBS is required to make payment under a CDS).

Assets Held as Collateral or by Third Parties

See discussion above on collateral in Payment/Performance Risk section.

Disclosures in Future Filings

In Comment Nos. 3, 4 and 5 the Staff has asked UBS to consider disclosing in future filings a
variety of information regarding credit derivatives. We note that peer banks subject to US GAAP
are providing more information regarding credit derivatives in response to new detailed disclosure
requirements becoming effective for their 2009 external financial reports. IFRS 7, Financial
Instruments: Disclosures, does not contain similar detailed disclosure requirements for credit
derivatives; however, voluntarily providing additional information might be beneficial. We expect
to disclose in future filings high-level textual information concerning the points above.

Comment 4

Note 23 Derivative instruments and hedge accounting, page 312

For credit protection sold and credit protection purchased, please tell us and consider disclosing
in future filings the extent to which the derivative activity was for the following purposes:

    •

    Providing default risk protection to offset credit exposure to your holdings of the related
reference entity’s debt in your loan portfolio, investment portfolio, or loan commitments
outstanding;

    •

    Creating new credit exposure for your own trading purposes;

    •

    Reflecting credit exposures taken for the benefit of your clients; and

    •

    Providing an offset to credit exposure taken for the benefit of clients.

Also, please discuss your overall strategies employed in your credit derivatives portfolio as well
as any changes in those strategies during the periods presented.

UBS actively utilizes CDS to economically hedge specific counterparty credit risks in its banking
book loan portfolios (including loan commitments) with the aim of reducing concentrations in
individual names, sectors or specific portfolios. As of June 30, 2009, UBS had purchased
approximately CHF 46.3 billion of CDS hedges against its banking book loan exposures of CHF 93.6
billion. In addition, UBS actively utilizes CDS to economically hedge specific counterparty credit
risks in its OTC derivatives portfolios.

UBS AG

Form 20-F for the fiscal year ended

December 31, 2008

Filed March 11, 2009

File Number 001-15060

October 23, 2009

Page 5 of 17

UBS is an active dealer in fixed income instruments and CDS and related products with respect to a
large number of securities issuers. The primary purpose of those activities is for the benefit of
UBS’s clients (market-making) and to a lesser extent creating new credit exposures taken for UBS’s
own trading purposes (proprietary trading).

Market-making activity consists of buying and selling single-name CDS, index CDS, loan CDS and
related referenced cash instruments to facilitate client trading activity. Proprietary trading
consists of trading in single-name CDS, index CDS and loan CDS to capitalize on pricing
discrepancies between various credit instruments (bonds, loans and equities) across investment
grade, high-yield and emerging markets.

As a general matter, risk to the relevant issuers arising from both fixed income instruments and
CDS and related products are reviewed and risk-managed on a net exposure basis (i.e. taking into
account all exposures to a particular issuer arising from both fixed income instruments and CDS and
related products) across market-making and proprietary trading activities.

The only significant change in UBS’s strategies with respect to CDS trading is the reduction in
scope and scale of the firm’s structured credit, proprietary credit and asset securitization
(including synthetic

Mail Stop 3010
          September 23, 2009
Mr. John Cryan Group Chief Financial Officer UBS AG  Bahnhofstrasse 45 CH-8001 Zurich,  Switzerland

Re: UBS AG
 Form 20-F for the fiscal year ended December 31, 2008
 Filed March 11, 2009
File No. 001-15060

Dear Mr. Cryan:
We have reviewed your filing and have the following comments.  Please be as
detailed as necessary in your explanations.  In our comments, we may ask you to provide
us with information so we may better unders tand your disclosure.  After reviewing this
information, we may raise additional comments.
 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 20-F for the year ended December 31, 2008

 Off-Balance Sheet, page 47

 Support to non-consolidated investment funds, page 50

 1. You disclose that in 2008, as a result of  the financial markets crisis which caused
declining asset values, market illiquidity and de-leveraging by investors, you supported several non-consolidated invest ment funds that you manage in your
wealth and asset management businesses.  Please tell us if your reassessed your
treatment of these funds for consolidation as a result of  the additional support and
provide us with the results of your  reassessments, if applicable.

Mr. John Cryan
UBS AG September 23, 2009 Page 2   Credit Risk, page 134

 Past due but not impaired loans, page 145

 2. We note that past due but not impaired loans that are 61-90 days old and over 90
days old increased significantly from year to year.  Please discuss this trend and
tell us in more detail how you determined that these loans were not impaired.
 Note 23 Derivative instrument s and hedge accounting, page 312

 3. We note your disclosure regarding your cr edit derivatives in Note 23.  Concerning
your involvement as a seller of credit deri vatives, please tell us, and disclose the
following information in future filings fo r your credit default swaps and total rate
of return swaps:

• Discuss the types of credit events or circumstances that would require you
to perform under the credit derivativ es and the current status of the
payment/performance risk of the credit derivatives;
• Discuss the nature of (1) any recourse  provisions that would enable you to
recover from third parties any of  the amounts paid under the credit
derivatives and (2) any assets held ei ther as collateral or by third parties
that, upon the occurrence of any speci fied triggering event or condition
under the credit derivative, you can obtain and liquidate  to recover all or a
portion of the amounts paid under the cred it derivative.  Plea se indicate, if
estimable, the approximate extent to which the proceeds from liquidation of those assets would be expected to cover the maximum potential amount
of future payments under the credit derivative.  In your estimate of
possible recoveries, please tell us the effect of purchase d credit protection
with identical underlying(s).
 4. For credit protection sold and credit protection purchased, please tell us and
consider disclosing in future filings the extent to which the derivative activity was for the following purposes:

• Providing default risk protection to o ffset credit exposure to your holdings
of the related reference entity’s debt  in your loan portf olio, investment
portfolio, or loan commitments outstanding;
• Creating new credit exposure fo r your own trading purposes;
• Reflecting credit exposures taken for the benefit of your clients; and
• Providing an offset to credit exposure taken for the benefit of clients.

Also, please discuss your overall strategies employed in your credit derivatives
portfolio as well as any changes in those strategies during the periods presented.

Mr. John Cryan
UBS AG September 23, 2009 Page 3

5. In addition to the above, please tell us and consider disclosing the following
information in future filings rela ted to your credit derivatives:

• Discuss any trends experienced within the portfolio both in terms of positions
held and realized gains and losses. Specifically disclose the reasons for the significant changes in the notional amounts as well as the reasons for the
changes in the fair values of the credit derivatives. Discuss any expected
changes to those trends.
• Discuss the types of counterparties (e.g. broker-dealers, other financial
institutions, non-financial institutions, and insurance and financial guaranty
firms) to your credit protection purchased. Consider quantifying the notional amount of credit derivatives by type of counterparty, separated between
whether you purchased protection from the counterparty or sold protection to
the counterparty.

6. You disclose on page 323 that you reflect  your own credit changes in valuations
for those financial liabilities at fair va lue, including derivativ e liabilities, where
your own credit risk would be considered  by market participants and excludes
fully collateralized transactions and othe r instruments for which it is established
market practice not to include an entity-s pecific adjustment for own credit.  Please
specifically tell us if you believe that your  own credit risk is c onsidered by market
participants as it relates to  the valuation of your deri vatives and tell us during
which periods you made adjustments to your derivative valuations due to your
own credit.
 Note 26 Fair value of financial instruments, page 322

7. We note your fair value disclosures in  Note 26 of your Form 20-F and your
disclosures in your Quarterly Report 2Q 09 included in your Form 6-K filed
August 4, 2009.  You discuss and/or present movements in Level 3 instruments based on three categories: trading portfo lio assets, derivative instruments, and
financial liabilities designated at fair value.  Please te ll us what consideration you
gave to further breaking these categories down into additional classes of financial
instruments.  Please provide us with your  proposed revised disclosure for future
filings, if applicable.
 8. We note your discussion on page 325 of mate rial changes in Level 3 instruments
for the year.  You state that there were transfers into Level 3, because valuation
inputs became less observable.  Please te ll us the significant sp ecific inputs that
became unobservable and consider expandi ng your disclosure to discuss the
specific inputs in future filings.

Mr. John Cryan
UBS AG September 23, 2009 Page 4   Note 29 Measurement categories of financial assets and financial liabilities, page 331

 b) Reclassification of financial assets, page 332

9. You disclose that the reclassification of th ese financial assets reflects your change
in intent and ability to hold these financia l assets for the foreseeable future rather
than for trading in the near term.  Please tell us in detail and discuss in future filings how you defined foreseeable futu re on the date of reclassification.
Additionally, please quantif y the numeric time period used for evaluating the
foreseeable future and discuss if it varied by asset type.
 Note 38 Reorganizations and disposals, page 358

 Sale of US residential mo rtgage-backed securities to BlackRock fund, page 358

 10. Please tell us how you accounted for the sale of RMBS to the RMBS
Opportunities Master Fund, LP.  Please tell us how you determined it was appropriate to derecognize the financial assets transferred, an d provide us with
any analysis you performed.  Additionally, te ll us, and disclose in future filings,
the fair value of the coll ateral securing the loan, a nd the payment terms of the
loan.  Furthermore, your disclosure on page 39 of your Form 6-K filed on August
4, 2009, indicates that the payment stream s to the SPE have slowed due to
declines in floating interest rate paym ents and increasing mortgage defaults.
Please discuss the impact that this slowi ng of payments to the SPE has had on the
payments being received on the loan from the SPE and the impact it has had on your analysis regarding the cons olidation status of the fund.
 11. You disclose that the USD 15 billion proceeds were approximately in line with
the fair value of the assets reco rded by UBS at 31 March 2008.  Please
specifically tell us how you determined the fair value of the assets transferred;
discuss how you incorporated any in surance from monolines, etc.

Sale of assets to a third-party fund contro lled by the Swiss National Bank (SNB), page
358
 12. Please tell us how you accounted for the sale  of securities and other positions to a
fund owned and controlled by the Swiss National Bank.  Please tell us how you
determined it was appropriate to derec ognize the financial assets transferred, and
provide us with any analysis you perform ed.  In particular, tell us how you
considered the guarantee made to the SNB, entitling the SNB to receive 100 million UBS ordinary shares if the SNB in curs a loss on the loan it has made to
the fund.  Please cite the specific guidance that you relied upon to determine the
appropriate accounting for this transaction.

Mr. John Cryan
UBS AG September 23, 2009 Page 5   13. You disclose on page 16 of your An nual Report 2008 that the value of the
securities as of 30 September 2008 was determined by the SNB based on a valuation conducted by third-party valuati on experts, and that you recorded a loss
equal to the difference between the valu e that you had previously assigned to
these securities and the value assigned by th e third-party experts.  Please tell us
how you considered Securities Act Rule 436 when determining whether you were required to name the experts and obtain th eir consents for inclusion in your filing
which is incorporated by reference in to several registration statements.
 Form 6-K filed August 4, 2009

14. Please tell us the extent to which your results for the six months ended June 30,
2009 were impacted by the early settlement  of derivative contracts where the
counterparty was AIG.  If your results we re impacted by such activities, please
tell us and revise your future filings to  discuss the circumstances surrounding the
settlements, quantify the no tional amount of the contract s involved, the amount of
the gain or loss upon early settlement, and identify the line item in which such amounts are presented.
 Risk Management and control, page 36

Credit risk, page 36
 15. You disclose that effective 1 Apr il 2009, you implemented a new policy for
designating a reclassified security as an  “impaired loan” and that you restated
your Investment Bank impaired lending portf olio to reflect the new policy.  Please
explain to us the reason for the new policy and how you determined that this new policy is the most appropriate.  Also te ll us what your polic y was prior to the
change related to these instruments.
 Note 9 Income Taxes, page 69

 16. You disclose that you recognized a deferred tax benefit of CHF 371 million,
which mainly relates to a release of va luation allowances against deferred tax
assets in respect of tax losses and tem porary differences, taking into account the
latest forecasts of taxable profits.  Please provide us with more detail regarding
how you determined that it was appropria te to release this portion of your
valuation allowance.  Tell us the positive criteria that you considered and tell us
any significant assumptions that you relied upon.

Mr. John Cryan
UBS AG September 23, 2009 Page 6   Note 11 Fair value of financial instruments, page 70

 17. You disclose on page 61 that you have  included the relevant fair value
requirements from IFRS 7 Amendment “Improving Disclosures about Financial Instruments” in Note 11.  In future fili ngs please also disclose the following: the
location of gains/losses in th e statement of comprehensive income or the separate
income statement, significant transfers between Level 1 and Level 2, and the amount of gains/losses attribut able to assets and liabiliti es held at the end of the
reporting period.  Please pr ovide us with your proposed revised disclosure for
future filings.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
response that keys your response to ou r comments and provides any requested
information.  Detailed cover le tters greatly facilitate our re view.  Please understand that
we may have additional comments after re viewing your responses to our comments.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Mr. John Cryan
UBS AG September 23, 2009 Page 7
If you have any questions, you may contact  Eric McPhee at (202) 551-3693 or me
at (202) 551-3782.

Sincerely,    Jessica Barberich
Assistant Chief Accountant

Mail Stop 4561

         November 1, 2006

Mr. Clive Standish
Chief Financial Officer
UBS AG
Aeschenvorstadt 1,
CH-4051 Basel, Switzerland

RE: UBS AG
Form 20-F for the Fiscal Ye ar Ended December 31, 2005
Filed March 21, 2006
File No. 1-15060

Dear Mr. Standish:

 We have completed our review of your Form 20-F and have no further comments
at this time.

        S i n c e r e l y ,

Joyce Sweeney
        S e n i o r  A c c o u n t a n t

<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
[UBS LOGO]                                     UBS AG
                                               Postfach
                                               CH-8098 Zurich
                                               Tel. +41-44-234 11 11

                                               Group Accounting Policies

                                               Will Widdowson
                                               Stockerstrasse 64
Via EDGAR and messenger                        Tel. +41-1-234 55 65
                                               Fax  +41-1-234 20 44
Ms Joyce Sweeney                               will.widdowson@ubs.com
Senior Accountant
Division of Corporation Finance                www.ubs.com
United States Securities and Exchange
Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, D.C. 20549

20 October 2006

UBS AG
FORM 20-F FOR THE YEAR ENDED DECEMBER 31, 2005
FILED MARCH 21, 2006
FILE NUMBER 001-15060

Dear Ms Sweeney

We respectfully submit the responses set forth below to the comment letter dated
September 21, 2006 (the "Comment Letter") from the staff (the "Staff") of the
Securities and Exchange Commission (the "Commission") relating to the Annual
Report on Form 20-F for the fiscal year ended December 31, 2005 (the "2005 Form
20-F") of UBS AG (the "Company"). For your convenience, we have set out the text
of each comment contained in the Comment Letter, followed by our response. As
you requested, we have included supplemental information where applicable and
will make every effort to comply with your comments in the Company's future
filings.

COMMENT 1
UBS financial highlights, page 2
--------------------------------
We note the Form 20-F available to investors on your website includes the
following financial measures that exclude goodwill amortization: earnings per
share, return on equity, net profit and cost/income ratio. Your Form 20-F filed
with the Commission does not include these measures. In your March 25, 2004
correspondence to the Staff you agreed to omit these measures from future
filings. Please revise the Form 20-F available on your website to conform
exactly to your Form 20-F as filed with the Commission.

RESPONSE
We note that in discussions with your Staff it was subsequently acknowledged
that the Form 20-F on our website is not different from the Form 20-F as filed
with the Commission. However, we wish to advise you that one of the documents
included in the filing did inadvertently contain certain pre-goodwill numbers
(see page 2 of the Handbook 2005/2006), although we do not cross-reference that
information in our responses to the financial data items required by Form 20-F.
Our cross references in the wrap-around document in our Form 20-F refer only to
the Financial Report 2005, which does not
<PAGE>
                                                  UBS AG
                                                  Form 20-F for the Year Ended
                                                  December 31, 2005
                                                  Filed March 21, 2006
                                                  File Number 001-15060
                                                  20 October 2006
                                                  Page 2 of 10

contain pre-goodwill numbers. We will recheck future filings to avoid including
such information, whether in the cross-referenced text or in the other text
included in the filed documents.

COMMENT 2
Results, page 20
----------------
In future filings please disclose the total amount or percentage of trading
revenues recognized attributable to proprietary trading on your own behalf for
each period presented. Please provide us with your proposed future disclosure.

RESPONSE
While we note your request that our future filings include the total amount or
percentage of trading revenues attributable to proprietary trading we
respectfully suggest that a narrative explanation within the Management
Discussion and Analysis part of our Financial Reporting is the most appropriate
way of explaining the significance of proprietary trading results. Our belief is
based on the following:

   1. We are not aware of any explicit requirement for the disclosure of
      proprietary trading revenues in either relevant accounting standards or
      the SEC regulations applicable to the Company. While we acknowledge the
      general requirement to provide sufficient information to enable users to
      properly understand the Company's financial position we do not see any
      explicit requirement for numerical data and would read the regulations as
      permitting narrative explanation.

   2. We are not aware of a consistent, generally accepted definition of
      "proprietary trading revenues". Indeed, we believe it would be difficult
      to achieve consensus on such a consistent definition. For example, a
      market making trading book in which an investment bank risk manages
      transactions arising in the normal course of providing liquidity to
      securities markets will record trading revenues, interest/dividend income
      and interest expense. Part of these may be attributable to the risks borne
      by the book, which might be regarded as proprietary in nature. Another
      part may be attributable to the margin made on customer flow business.
      Because such trading activities are risk managed on an integrated basis it
      is difficult to define the proprietary component and attribute
      revenues/costs to that component. Our internal reporting follows from the
      way in which this business is managed; combined figures for trading
      revenues are reported to senior management.

   3. In the absence of a consistent industry wide definition of proprietary
      trading we have some difficulty with seeing how numerical disclosure would
      provide more useful information than a narrative description of
      significant developments in the proprietary trading area. We also have
      reservations about the disclosure of numerical data which may not be
      comparable with any potential future numerical disclosure made by our
      peers in the financial services industry by reason of differing
      definitions of proprietary trading.

   4. We are not aware that other registrants in our peer group are disclosing a
      total amount or percentage of trading income derived from proprietary
      trading activities in their external financial reports. Some make
      qualitative comments in similar ways as we do in our MD&A or in analyst
      presentations. In the past, our practice was to include a comment on
      proprietary trading in periods where revenues from proprietary trading
      activities were one of the drivers of the result when compared with prior
      periods. Such comments on proprietary trading were not based on a
      comprehensive analysis of our proprietary trading revenues, but rather on
      the results of certain risk positions that may have performed well above
      or below average in a given period.

For the above reasons, we respectfully ask you to consider favorably our
proposal to continue to provide narrative explanation of significant profit/loss
developments in relation to risks which might be considered to be of a
proprietary nature.
<PAGE>

                                                  UBS AG
                                                  Form 20-F for the Year Ended
                                                  December 31, 2005
                                                  Filed March 21, 2006
                                                  File Number 001-15060
                                                  20 October 2006
                                                  Page 3 of 10

COMMENT 3
Industrial Holdings, page 56
----------------------------
We note your disclosure of the performance indicator titled "Investment" and the
footnote description of the components used to arrive at the measure. Based on
the disclosure included in this section of your document it is not clear how the
relative significance of the components (historical cost of investments made,
less divestments and impairments) impacts the performance indicator or how a
reader should interpret this information. In future filings please quantify the
components of this performance indicator for the periods presented and include a
narrative discussion of how the company uses this information as an indicator of
performance for your Industrial Holdings segment. Please provide us with your
proposed future disclosure.

RESPONSE
In future filings, we will include information on "Unrecognized gains". We
believe this provides a better measure of performance for this business. We will
keep the disclosure on the size of our investment, because its development shows
the progress we make in winding down our private equity portfolio, which is our
declared strategy for this business. In addition, in our 2006 Annual Report, we
will remove any key performance indicators for the Industrial Holdings segment,
because that segment is no longer material to the Company. The disclosure that
we plan to make with respect to private equity investments is therefore
considered complementary information and will look as follows:

   PRIVATE EQUITY
   CHF billion                      31.12.06         31.12.05         31.12.04
   Investments, at cost                  X.X              0.7              1.2
   Portfolio fair value                  X.X              1.0              1.7
   Unrecognized gains                    X.X              0.3              0.5

COMMENT 4
Note 1 - Summary of Significant Accounting Policies
---------------------------------------------------
In future filings please describe the composition of your statement of
operations line item "Revenues from industrial holdings" and "Goods and
materials purchased" and describe your related accounting policies. Quantify the
components of the revenue line item for the periods presented in your financial
statement footnotes or management's discussion and analysis section of your
document. Please provide us with your proposed future disclosure.

RESPONSE
In future filings we will include a description of our accounting policies
related to "Revenues from industrial holdings" and "Goods and materials
purchased" in Note 1. The text we plan to include reads as follows:

Revenues from industrial holdings include sales of goods and services from six
consolidated entities and are derived from various businesses. Revenue is
recognized upon customer acceptance of goods delivered and when services have
been rendered. Goods and materials purchased include costs for raw materials,
parts and finished goods purchased from third party suppliers to produce the
goods and services sold.

We would like to make the Staff aware that on 23 March 2006 we sold our entire
interest in Motor-Columbus, the company that most significantly contributed to
the line items "Revenues from industrial holdings" and "Goods and materials
purchased". On 2 June 2006, after the sale of Motor-Columbus we submitted a
restated Financial Report 2005 on Form 6-K to present Motor-Columbus as a
discontinued operation. Subsequent to that submission, we completed the disposal
of two additional companies of the Industrial Holdings segment in the second and
third quarter 2006. The companies in the Industrial Holdings segment were all
purchased with a view to their subsequent resale and those

<PAGE>

                                                  UBS AG
                                                  Form 20-F for the Year Ended
                                                  December 31, 2005
                                                  Filed March 21, 2006
                                                  File Number 001-15060
                                                  20 October 2006
                                                  Page 4 of 10

that have been sold are presented as discontinued operations in accordance with
IFRS 5. This change in presentation has the following effect if 2005 and 2004
are restated at 30 September 2006:

                                          Restated              Pre-restatement
CHF million                           2005        2004         2005        2004
                                     -----------------       ------------------
Revenues from industrial holdings    1,137       1,774       10,515       6,086
Goods and material purchased           493         679        8,003       3,885

In view of the size of the restated figures we trust that you will agree that
the proposed level of disclosure is sufficient and that a quantification of the
components would place unjustified emphasis on these figures.

COMMENT 5
e) Securitizations, page 81
---------------------------
We note your disclosures in Note 1(e) and (f) that you may hold retained
interests in securitized assets in the form of servicing assets/liabilities,
senior or subordinated tranches, interest only strips or other residual
interests. We also note your Note 33 on page 156 only quantifies the carrying
value of retained interests in agency mortgage securities. In future filings
please quantify, if material, the carrying values of each type of retained
interest and any associated liability related to your continuing involvement for
derecognition and securitization transactions. For the periods presented, please
provide us with your proposed future disclosure. Refer to paragraph 94(a) of IAS
32.

RESPONSE
We would like to advise the staff that at 31 December 2005, 2004 and 2003 we did
not hold material retained interests in securitized assets in the form of
servicing assets/liabilities, senior or subordinated tranches, interest only
strips or other residual interests, except retained interests in agency mortgage
securities, which we disclosed. In future filings, we will remove in Note 1 the
reference to all forms of retained interests where we do not have material
amounts. We also would like to point the staff to Note 29(e) of our financial
statements where we provide the disclosures asked for by paragraph 94(a) of IAS
32.

COMMENT 6
p) Loans, page 84
-----------------
We note you amortize fees and direct costs relating to loan origination,
refinancing, restructuring and loan commitments to interest income over the life
of the loan using the straight-line method and that this method approximates the
effective interest method. Please tell us the following:

     o   how you determine the period of time (expected life or contractual life
         of the loan) over which you amortize these fees and costs; and
     o   how you determined that the difference between using the straight-line
         method and using the effective interest method is not material for the
         periods presented.

Refer to paragraphs 9, 46 and AG5 - AG8 of IAS 39.

RESPONSE
Before we respond directly to the Staff's comment, we would like to advise the
Staff of the customary terms under which the Company issues loans to its
customers to provide appropriate context for our response. We believe that
without this information it may be difficult for the Staff to assess the
appropriateness of our accounting policies.

The lending activities of UBS are almost exclusively conducted through two of
our Business Groups, Global Wealth Management & Business Banking ("GWMBB") and
Investment Bank ("IB"). GWMBB
<PAGE>
                                                  UBS AG
                                                  Form 20-F for the Year Ended
                                                  December 31, 2005
                                                  Filed March 21, 2006
                                                  File Number 001-15060

<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
[UBS LOGO]                                     UBS AG
                                               Postfach
                                               CH-8098 Zurich
                                               Tel. +41-44-234 11 11

                                               Clive Standish
                                               Chief Financial Officer
                                               Bahnhofstrasse 45,
                                               8001 Zurich
CONFIDENTIAL                                   Tel. +41-44 234-4046
                                               Fax  +41-44 234-2100
                                               clive.standish@ubs.com

                                               www.ubs.com
Ms. Cecilia D. Blye
Chief Office of Global Security Risk
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549-5546
United States of America

6 September 2006

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. 200.83

Dear Ms. Blye

We are responding to your letter of June 8, 2006 to our Chief Financial Officer
Mr. Clive Standish regarding our Forms 20-F for the fiscal years ending December
31, 2004 and 2005 and our letters to you dated November 16, 2005 and April 20,
2006.

The responses to the specific questions raised in your letter are set out below
in detail. We thought it may be helpful if we first offer a broad description of
UBS's overall approach to questions of global security risk more generally in
the context of our wider anti-money laundering (including counter terrorist
financing) efforts.

Like many banks and reflecting globally accepted anti-money laundering
standards, UBS AG and its consolidated subsidiaries (collectively referred to
here as "UBS") have implemented globally a systematic approach to evaluating and
mitigating the risks relating to clients and their activities based on their
country connections. This is in addition to, and in concert with, the evaluation
of other client specific risks such as whether they have connections to
sensitive industries or activities or are "politically exposed persons" and the
products used/transactions undertaken by the client.

UBS analyzes every country and assesses its political, social and economic
stability; the vulnerability of the country to financial crimes such as
corruption, organized crime, money laundering and terrorism finance, and the
response the country takes to address and fight against such crimes. To
structure this analysis we use a number of data sources, which we assess and
assign a numeric scale of 1 to 4 against each indicator. We then weight the
resulting aggregate scores, giving particular emphasis to terrorism, money
laundering, and corruption related indicators and a weighted average is
calculated for each country. If the resulting score is less than 2.49, the
country is considered "not sensitive," while a score of between 2.50 and 4.00
means that the country is regarded as "sensitive." The assessment of every
country is reviewed annually and, at present, over 100 countries are regarded as
"sensitive".

UBS will only enter into relationships involving parties connected to sensitive
countries (e.g. by reference to their domicile, place of business etc.) if we
are comfortable that appropriate controls are in place to monitor and manage the
relationship and where the nature of the relationship, the parties involved, and
the purpose of the activities have all been properly vetted. While the exact
nature of these controls depends on the country in question, the nature of the
client and the business they
<PAGE>
[UBS LOGO]
CONFIDENTIAL TREATMENT REQUESTED BY UBS AG                September 6, 2006
                                                          Page 2 of 5

propose to undertake with UBS, they include e.g. enhanced due diligence/
screening and additional levels of approvals before we will do business with
that party, enhanced monitoring of the relationship and the transactions
undertaken and more frequent reviews of the relationship generally.

In addition, and as referenced in our previous letters, UBS has also established
a comprehensive and global economics sanctions policy, which we believe is
unique amongst international financial institutions in its comprehensive scope
and global application. This policy combines the effects of U.S., E.U., U.N. and
Swiss restrictions imposed against countries, specific government regimes,
designated terrorists and others (such as identified narcotics traffickers, and
those identified as being involved in the proliferation of weapons of mass
destruction). These combined measures are then applied globally and also
supplemented by policy decisions taken by UBS as to the business we will and
will not do involving these countries (even if such business would otherwise be
permitted under all of the measures mentioned above). We refer to the overall
set of restrictions as "Extended Measures" under our group sanctions policy.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

By deliberately evaluating every country and weighting that evaluation heavily
around indicators focused on issues of terrorism, corruption, and
money-laundering, we are able to identify, isolate, and control the country
specific risks. We believe our approach to global security risk reflects the
concerns of investors, in the U.S. and elsewhere, for whom such risks are a
specific, significant, and important part of their investment decision-making.

With respect to your specific questions, we respond as follows (the numbers
introducing the paragraphs in bold type below cross-refer to the numbering of
your questions - but we have grouped parts of your questions together where we
believe this makes sense):

1.       WE NOTE THE STATEMENT IN YOUR [APRIL 20, 2006] RESPONSE THAT YOU WILL
         CONTINUE TO HAVE LIMITED CONTACTS WITH IRAN AND CUBA, INCLUDING "OTHER
         TRANSACTIONS FORMALLY LICENSED OR PERMITTED BY THE U.S. OFFICE OF
         FOREIGN ASSETS CONTROL ("OFAC") AND/OR U.S. LAW." PLEASE CLARIFY
         FURTHER FOR US THE TYPES OF TRANSACTIONS THAT MAY BE COVERED BY THIS
         REFERENCE; AND

4.       TO THE EXTENT THAT THE INFORMATION IN YOUR APRIL 20, 2006 RESPONSE
         REGARDING YOUR ANTICIPATED FUTURE CONTACTS WITH CUBA AND IRAN IS ALSO
         DESCRIPTIVE OF YOUR ANTICIPATED FUTURE CONTACTS WITH SYRIA, SUDAN, AND
         NORTH KOREA, PLEASE ADDRESS YOUR ANTICIPATED CONTACTS WITH THOSE
         COUNTRIES IN YOUR RESPONSE TO COMMENT 1 ABOVE.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

While one of the primary factors for determining whether a transaction or
relationship involving one of these countries may be permitted is whether it is
lawful under OFAC and/or U.S. law (whether or not a U.S. person is involved),
this is NOT the only factor. Even when the activity would be lawful under U.S.
law, the nature of the relationship, the parties and connected persons involved,
the ability to monitor activity, the underlying purpose of the relationship, and
the type of financial services to be provided are all also important parts of
every analysis involving one of these countries. Only under very limited
circumstances would UBS view activities involving these countries as acceptable.

Because the scope of business permitted under our "Extended Measures" is so
narrowly and carefully defined, our policy requires that ANY proposed business
activity involving these countries be the subject of a specific review by the
relevant business' Compliance Department and may only

<PAGE>
[UBS LOGO]
CONFIDENTIAL TREATMENT REQUESTED BY UBS AG                September 6, 2006
                                                          Page 3 of 5

be undertaken if agreed by them based on our globally applicable guidance. It is
beyond the scope of this letter to provide a comprehensive inventory of the
types of transactions that may be acceptable to UBS, but, by way of example,
this may include transactions involving these countries, to the extent they are
not restricted by any of these programs, such as the processing of payments to
the United Nations and other international organizations licensed by OFAC;
financial services related to the export of medicine, and medical supplies
(being consistent e.g. with OFAC licenses and regulations); and financial
transactions necessary and incidental to the performance of services to these
countries that are exempt from OFAC regulation such as the those related to the
free and open exchange of ideas and the export of humanitarian goods.

         IN THIS REGARD, WE NOTE THAT THE TRANSACTIONS OF THE TYPES YOU HAVE
         STATED YOU WILL TERMINATE MIGHT BE DEEMED TO BE "PERMITTED" BY U.S.
         LAW, TO THE EXTENT THEY ARE UNDERTAKEN BY YOUR NON-U.S. SUBSIDIARIES
         WITHOUT PARTICIPATION BY U.S. PERSONS.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

         WITH REGARD TO YOUR REFERENCE TO THE LEGALITY OF THE LIMITED CONTACTS
         YOU WILL CONTINUE TO HAVE WITH CUBA AND IRAN, WE NOTE THAT THE RISK
         THAT BUSINESS CONTACTS WITH TERRORIST-SPONSORING STATES WILL NEGATIVELY
         IMPACT A CORPORATION'S REPUTATION AND SHARE VALUE MAY EXIST WITH
         RESPECT TO CONTACTS THAT ARE LAWFUL. PLEASE EXPAND YOUR MATERIALITY
         ANALYSIS TO ADDRESS THE POSSIBILITY THAT YOUR ONGOING CONTACTS WITH
         CUBA AND IRAN MAY NEGATIVELY IMPACT YOUR REPUTATION AND SHARE VALUE,
         NOTWITHSTANDING THAT SUCH CONTACTS MAY BE LAWFUL.

As described above, the evaluation of "lawfulness" in this context relates to an
assessment of whether the activity is one that would be permissible under all
relevant U.S., Swiss, E.U and United Nations measures as well as under our own
internal, policy driven decisions. In this way, we couple the decisions of
relevant governments and supra-national organisations with our own policy
position and a case-by-case analysis of the nature of the transactions and the
parties involved. We believe that our approach of aggregating the views of key
government and supra-national organisations as expressed in the various measures
they implement and aligning our policy to reflect the views of all of these
bodies in aggregate provides significant protection against negative impacts to
our reputation. Further, in deciding whether or not to undertake any new
business (or in deciding to continue any existing business rather than exiting)
even if it is legally permissible under all of these regimes, there is a
specific review of that business. This review includes a qualitative assessment
of whether that contact may negatively impact our reputation - making the
assumption that such business was publicly disclosed. Thus we believe our
approach embodies a qualitative assessment of the nature of UBS's contacts with
these countries and the impact of any such contact for our investors, including
as to the potential significance of such business to our investors and the
impact of such business on the information we provide to our investors.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

2.       WE NOTE THAT IN YOUR MARCH 2006 TESTIMONY BEFORE THE U.S. HOUSE OF
         REPRESENTATIVE'S INTERNATIONAL RELATIONS COMMITTEE'S SUBCOMMITTEE ON
         OVERSIGHT AND INVESTIGATION YOU DISCUSS BUSINESS CONTACTS IN SYRIA,
         SUDAN, AND NORTH KOREA. IN LIGHT OF THE FACT THAT SYRIA, SUDAN, AND
         NORTH KOREA HAVE BEEN IDENTIFIED BY THE U.S. STATE DEPARTMENT AS STATE
         SPONSORS OF TERRORISM, AND ARE SUBJECT TO U.S. ECONOMIC SANCTIONS,
         PLEASE DESCRIBE FOR US THE EXTENT AND NATURE OF YOUR PAST, CURRENT, AND
         ANTICIPATED CONTACTS WITH SYRIA, SUDAN, AND NORTH KOREA, THROUGH
         SUBSIDIARIES, AFFILIATES, OR OTHER DIRECT OR INDIRECT ARRANGEMENTS.
         DESCRIBE ANY CONTACTS WITH THE GOVERNMENTS OF SYRIA, SUDAN, AND NORTH
         KOREA, AND/OR ENTITIES CONTROLLED BY OR AFFILIATED WITH EITHER
         GOVERNMENT.

<PAGE>
[UBS LOGO]
CONFIDENTIAL TREATMENT REQUESTED BY UBS AG                September 6, 2006
                                                          Page 4 of 5

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

3.       PLEASE DISCUSS THE MATERIALITY TO YOU OF YOUR CONTACTS WITH SYRIA,
         SUDAN, AND NORTH KOREA, INDIVIDUALLY AND IN THE AGGREGATE, INCLUDING
         ALSO CONTACTS WITH IRAN AND CUBA, AND YOUR VIEW AS TO WHETHER THOSE
         CONTACTS, INDIVIDUALLY OR IN THE AGGREGATE, CONSTITUTE A MATERIAL
         INVESTMENT RISK FOR YOUR SECURITIES HOLDERS. PROVIDE BOTH YOUR
         CONCLUSIONS AND YOUR ANALYSIS.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION]

Whether individually or in aggregate, we remain of the view that the activity
described in this and our previous letters does not constitute (either
individually or in the aggregate) a material investment risk for our securities
holders. As explained above, we believe our approach embodies a qualitative
assessment of the nature of UBS's contacts with these countries and the impact
of any such contact for our investors, including as to the potential
significance of such business to our investors and the impact of such business
on the information we provide to our investors. We do not believe that a
reasonable investor would consider the totality of all quantitative and
qualitative factors related to UBS's activities involving these countries as
significant or important in making an investment decision or that the totality
of all quantitative and qualitative information regarding UBS's activities would
significantly alter the total mix of information available to a reasonable
investor. Further, UBS does not believe that its contacts and activities with
the named countries, either individually or in the aggregate, would constitute a
material investment risk to our securities holders. In size and amount, the
activity is immaterial and of virtually no economic relevance to the Group. In
relation to the impact of the state legislation that you mention, we remain of
the view that UBS's approach to dealings with these countries has taken into
account the aims of the legislation and embedded it within our policy of exiting
relationships and dealings with these countries and is very much aligned in
spirit to the aims of these laws. As mentioned in our letter of 20 April, we
have discussed the public statements that we have made about our policy on
dealings with these countries with certain state authorities and certain clients
and other interested parties regarding specific state law requirements. As a
result of these discussions, it is clear that the specific terms of each state's
law can (and do) differ substantially. To date however, we have found either
that the specific laws do not, by their terms, affect the ability of an investor
to invest in (or client to deal with) UBS or, when we have discussed matters
fully with relevant parties, the policies and measures we have put in place and
described in this letter have been sufficient to address concerns. To date, we
are not aware that the very limited business involving these countries that we
have described in our letters to you has resulted in any investor having to
divest of their interest in UBS or that such activity has resulted in any
existing client ceasing to deal with us as a result of such activity.

CONCLUSIONS

As described, UBS has adopted and continues to implement policies in all of its
operations worl

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      June 8, 2006

Via U.S. Mail and Facsimile

Clive Standish
Chief Financial Officer
UBS AG
Bahnhofstrasse 45
8001 Zurich
Switzerland

RE:	UBS AG
	20-F for the fiscal year ended December 31, 2004
	20-F for the fiscal year ended December 31, 2005
	Response letter dated November 16, 2005
	Response letter dated April 20, 2006
	File No. 1-15060

Dear Mr. Standish:

      We have reviewed your response letters and have the
following
comment.  We welcome any questions you may have about our comments
or
on any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

General -

1. We note the statement in your response that you will continue
to
have limited contacts with Iran and Cuba, including "other
transactions formally licensed or permitted by the US Office of
Foreign Assets Control (`OFAC`) and/or US law."  Please clarify
further for us the types of transactions that may be covered by
this
reference.   In this regard, we note that transactions of the
types
you have stated you will terminate might be deemed to be
"permitted"
by US law, to the extent they are undertaken by your non-US
subsidiaries without participation by US persons.

With regard to your reference to the legality of the limited
contacts
you will continue to have with Cuba and Iran, we note that the
risk
that business contacts with terrorist-sponsoring states will
negatively impact a corporation`s reputation and share value may
exist with respect to contacts that are lawful.  Please expand
your
materiality analysis to address the possibility that your ongoing
contacts with Cuba and Iran may negatively impact your reputation
and
share value, notwithstanding that such contacts may be lawful.

2. We note that in your March 2006 testimony before the U.S. House
of
Representative`s International Relations Committee`s Subcommittee
on
Oversight and Investigation you discuss business contacts in
Syria,
Sudan, and North Korea.  In light of the fact that Syria, Sudan,
and
North Korea have been identified by the U.S. State Department as
state sponsors of terrorism, and are subject to U.S. economic
sanctions, please describe for us the extent and nature of your
past,
current, and anticipated contacts with Syria, Sudan, and North
Korea,
through subsidiaries, affiliates, or other direct or indirect
arrangements.  Describe any contacts with the governments of
Syria,
Sudan, and North Korea, and/or entities controlled by or
affiliated
with either government.

3. Please discuss the materiality to you of your contacts with
Syria,
Sudan, and North Korea, individually and in the aggregate,
including
also contacts with Iran and Cuba, and your view as to whether
those
contacts, individually or in the aggregate, constitute a material
investment risk for your security holders.  Provide both your
conclusions and your underlying analysis.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
Arizona and Louisiana have adopted legislation that requires their
state retirement systems to prepare reports regarding state
pension
fund assets invested in, and/or permits divestment of state
pension
fund assets from, companies that do business with U.S.-designated
state sponsors of terrorism. Illinois, Maine, New Jersey and
Oregon
have adopted legislation requiring reporting of interests in, or
divestment from, companies that do business with Sudan, and
similar
legislation has been proposed by several other states.  Harvard
University, Yale University, Stanford University and other
educational institutions have adopted policies prohibiting
investment
in, and/or requiring divestment from, companies that do business
with
Sudan.  Your materiality analysis should address the potential
impact
of the investor sentiment evidenced by these actions.

4. To the extent that the information in your April 20, 2006,
response regarding your anticipated future contacts with Cuba and
Iran is also descriptive of your anticipated future contacts with
Syria, Sudan and North Korea, please address your anticipated
contacts with those countries in your response to comment 1 above.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please file your response
letter on EDGAR.

      Please contact Jack Guggenheim at (202) 551-3523 if you have
any questions about the comment or our review.  You may also
contact
me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	John Cusak
	Group Compliance
	UBS AG
	St. Annagasse 9
	P.O. Box
	CH-8098
	Zurich, Switzerland

	cc: 	Todd Shiffman
		Assistant Director
		Division of Corporation Finance
Clive Standish
UBS AG
June 8, 2006
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

							September 20, 2005

Via U.S. Mail
Peter A. Wuffli
Chief Executive Officer
UBS AG
Bahnhofstrasse 45
CH-8098
Zurich, Switzerland

RE:		UBS AG
      Form 20-F for the fiscal year ended December 31, 2004
		File No. 1-15060

Dear Mr. Wuffli:

      We have reviewed the above filing and have the following
comment.  We have limited our review of your Form 20-F to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 20-F.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone number
listed
at the end of this letter.

General

We note from publicly available sources that last year you were
fined
$100 million by the U.S. Federal Reserve as a penalty for engaging
in
USD banknote transactions with countries subject to sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control, including Cuba, Iran and Libya.  Please advise us
whether you have engaged or currently engage, directly or
indirectly,
in other transactions, including financing or credit arrangements,
in
or with Cuba, Iran and/or Libya.  If so, please briefly describe
for
us the nature of your operations and customer relationships in
each
country.  Advise us whether your customers include or have
included
the governments of these countries, or enterprises controlled by
the
governments of these countries.  In view of the fact that Cuba,
Iran
and Libya have been identified by the U.S. State Department as
state
sponsors of terrorism, and Cuba and Iran are subject to OFAC-
administered economic sanctions, please advise us of the
materiality
of your contacts with these countries, and give us your view as to
whether those contacts, individually or in the aggregate,
constitute
a material investment risk for your securityholders.

In preparing your response, please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
legislation requiring divestment from, or reporting of interests
in,
companies that do business with U.S.-designated state sponsors of
terrorism has been adopted by Arizona and Louisiana.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comment, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.
      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Frank Green
at
(202) 551-3522 if you have any questions about the comment or our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Todd Shiffman
		Assistant Director
		Division of Corporation Finance

Peter A. Wuffli
UBS AG
September 20, 2005
Page 1

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
[UBS LOGO]
                                              UBS AG
                                              Postfach
                                              CH-8098 Zurich
                                              Tel. +41-44-234 11 11

                                              Clive Standish
                                              Group Chief Financial Officer
                                              Bahnhofstrasse 45,
                                              8001 Zurich
                                              Tel. +41-44 234-4046
                                              Fax  +41-44 234-2100
                                              clive.standish@ubs.com

                                              www.ubs.com
Ms Cecilia D. Blye
Chief Office of Global Security Risk
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549-5546
United States of America

20 April 2006

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. Sec. 200.83

Dear Ms Blye

We are responding to your letter of 28 March to our Chief Financial Officer,
Clive Standish regarding our letter to you of 16 November 2005 on our Form 20-F
for the fiscal year ended 31 December 2004.

We are pleased to provide our answers to your further questions as set out
below. Where we defined terms in our earlier letter, they have the same meanings
in this letter.

QUESTION: "WE ARE AWARE OF PUBLISHED REPORTS THAT YOU HAVE STOPPED DOING
BUSINESS WITH IRAN. WE ALSO ARE AWARE OF PUBLISHED REPORTS THAT YOU WILL SELL
YOUR IRANIAN ACCOUNTS TO ANOTHER BANK IN WHICH YOU HOLD A CONTROLLING INTEREST.
PLEASE ADVISE US OF THE ACCURACY OF THESE REPORTS."

In relation to the reports that UBS has "stopped doing business with Iran",
these are generally accurate. As we described in our letter of 16 November, UBS
AG took the decision, for itself and its consolidated subsidiaries (the
"Group"), to reduce significantly its existing business relationships and
business activities in both Cuba and Iran. This is confirmed, for example also
in our recent testimony to the House International Relations Committee's
Subcommittee on Oversight and Investigation (see
http://wwwc.house.gov/international_relations/109/her032906.pdf ).

We deal with the question that we are "selling our Iranian accounts to another
bank in which we hold a controlling interest" below.

QUESTION: "IF THE REPORT THAT YOU HAVE STOPPED DOING BUSINESS WITH IRAN IS
CORRECT, PLEASE ADVISE US WHETHER THIS MEANS THAT (I) YOU HAVE TERMINATED AND/OR
WILL NOT ENTER INTO FURTHER "BANK RELATIONSHIPS" AND "FINANCING OR CREDIT
ARRANGEMENTS," AS DEFINED IN YOUR LETTER, WITH RESPECT TO IRANIAN PARTIES OR
TRANSACTIONS, AND (II) YOU WILL NOT OTHERWISE ENGAGE IN OR FACILITATE
TRANSACTIONS INVOLVING IRAN OR IRANIAN PARTIES.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION]

QUESTION: "WE ALSO ARE AWARE OF PUBLISHED REPORTS THAT YOU WILL SELL YOUR
IRANIAN ACCOUNTS TO ANOTHER BANK IN WHICH YOU HOLD A CONTROLLING INTEREST.
PLEASE ADVISE US OF THE ACCURACY OF THESE REPORTS."
<PAGE>

[UBS LOGO]
                                                   20 April 2006
CONFIDENTIAL TREATMENT REQUESTED BY UBS AG         Page 2 of 2

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION]

QUESTION: "IF THE REPORT THAT YOU WILL SELL YOUR IRANIAN ACCOUNTS TO A BANK IN
WHICH YOU HAVE A CONTROLLING INTEREST IS CORRECT, PLEASE ADDRESS FOR US THE
POTENTIAL IMPACT UPON YOUR REPUTATION AND SHARE VALUE OF YOUR CONTINUING TO HAVE
AN INDIRECT INTEREST IN THESE ACCOUNTS, IN LIGHT OF IRAN'S STATUS AS A COUNTRY
IDENTIFIED BY THE U.S. AS A STATE SPONSOR OF TERRORISM AND SUBJECT TO U.S.
ECONOMIC SANCTIONS. YOUR RESPONSE SHOULD ADDRESS THE U.S. INVESTOR SENTIMENT
EVIDENCED BY THE ARIZONA AND LOUISIANA LEGISLATION CITED IN OUR PREVIOUS LETTER,
AS WELL AS THE EXTENT OF YOUR U.S. CLIENT BASE AND U.S. SHAREHOLDER BASE.

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION]

YOU STATE IN YOUR NOVEMBER 16 LETTER THAT YOU DO NOT BELIEVE YOUR CONTACTS WITH
CUBA AND IRAN ARE MATERIAL WHEN CONSIDERED IN THE LIGHT OF QUALITATIVE FACTORS.
PLEASE ADDRESS THAT ISSUE IN LIGHT OF THE U.S. INVESTOR SENTIMENT EVIDENCED BY
THE ARIZONA AND LOUISIANA LEGISLATION CITED IN OUR PRIOR LETTER, AND YOUR U.S.
CLIENT BASE AND U.S. SHAREHOLDER BASE

[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION]

For these reasons, as well as those outlined in our earlier letter, we continue
to believe that our contacts with Cuba and Iran are not material (and will, of
course, continue to reduce in any event).

As requested in your letter of 28 March, we confirm our acknowledgement that:

o        UBS AG is responsible for the adequacy and accuracy of the disclosures
         in its filings;

o        Commission staff comments or changes to disclosure in response to staff
         comments do not foreclose the Commission from taking any action with
         respect to filings;

o        UBS AG may not assert staff comments as a defence in any proceeding
         initiated by the Commission or any person under the federal securities
         laws of the United States.

UBS AG requests that this letter be treated as confidential, and that we receive
timely notification and afforded an opportunity to object if any request for it
is received under the Freedom of Information Act or any other law, based on the
competitive damage that would arise from its release.

We are available to discuss this letter with you, should you so wish. If you
wish to contact us, we suggest you contact John Cusack of Group Compliance in
the first instance (UBS AG, St. Annagasse 9, PO Box, CH-8098, Zurich,
Switzerland).

Yours sincerely,

UBS AG

/s/ Clive Standish                                   /s/ Peter Kurer

Clive Standish                                       Peter Kurer
Group Chief Financial Officer                        Group General Counsel
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

SEC Response Letter 11/16/05

Ms.Cecilia D. Blye, Chief

Office of Global Security Risk

Division of Corporation Finance

Securities and Exchange Commission

Washington, D.C. 20549 – 5546

USA
UBS AG

Postfach

CH-8098 Zürich

Tel. +41-44-234 11 11

Clive Standish

Chief Financial Officer

Bahnhofstrasse 45

8001 Zurich

Tel. +41 44 234 4046

Fax. +41 44 234 2100

clive.standish@ubs.com

www.ubs.com

UBS AG HAS CLAIMED
CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN

ACCORDANCE WITH 17 C.F.R §200.83.

16 November 2005

Dear Ms Blye

We refer to your letter of 20
September 2005 addressed to our Chief Executive Officer, Peter Wuffli regarding UBS
AG’s Form 20-F for the fiscal year ended 31 December 2004. Set forth below are UBS
AG’s responses to your comment letter. To facilitate your review, we have reproduced
your comment below, in bold, italicized text.

“We note from publicly available sources that last year you were
fined $100 million by the U.S. Federal Reserve as a penalty for engaging in USD
banknote transactions with countries subject to sanctions administered by the
U.S. Treasury Department’s Office of Foreign Assets Control, including
Cuba, Iran and Libya. Please advise us whether you have engaged or currently
engage, directly or indirectly, in other transactions, including financing or
credit arrangements, in or with Cuba, Iran and/or Libya. If so, please briefly
describe for us the nature of your operations and customer relationships in each
country. Advise us whether your customers include or have included the
governments of these countries, or enterprises controlled by the governments of
these countries. In view of the fact that Cuba, Iran and Libya have been
identified by the U.S. State Department as state sponsors of terrorism, and Cuba
and Iran are subject to OFAC-administered economic sanctions, please advise us
of the materiality of your contacts with these countries, and give us your view
as to whether those contacts, individually or in the aggregate, constitute a
material investment risk for your securityholders.

In preparing your response please consider that evaluations of materiality
should not be based solely on quantitative factors, but should include
consideration of all factors that a reasonable investor would deem important in
making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value. In this regard, we
note that legislation requiring divestment from, or reporting of interest in,
companies that do business with U.S.-designated state sponsor of terrorism has
been adopted by Arizona and Louisiana.”

     CONFIDENTIAL TREATMENT REQUESTED BY UBS AG
     16 November 2005

Page 2 of 7

As we describe below in
section 1 of this letter, neither UBS AG nor any of its consolidated
subsidiaries (collectively, the “Group”) have any physical presence or
any employees in Cuba, Iran and/or Libya (collectively, the “Subject
Countries”). While we do have some transactions, operations or
relationships involving the Subject Countries (described in general terms in
section 2 and then described specifically by Subject Country in sections 3, 4
and 5 of this letter), (the “Subject Country Activities”), for the
reasons set out in this letter, we do not believe that our Subject Country
Activities, individually or in the aggregate, constitute a material or
potentially material risk to our security holders.

In terms of quantitative
materiality, in our assessment, the Subject Country Activities are immaterial.
Total Client Assets1 held on behalf of clients located in the
Subject Countries as at 31 December 2004 amounted to approximately [CONFIDENTIAL
INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND
EXCHANGE COMMISSION]2 (representing [CONFIDENTIAL INFORMATION HAS BEEN OMITTED
AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE
COMMISSION]3 of total Client Assets held by the UBS Group as of
that date). Revenues earned from those relationships in 2004 were approximately
[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION] (representing [CONFIDENTIAL INFORMATION HAS
BEEN OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION]
of Group revenues in the year).

As at 30 September 2005,
total Client Assets held on behalf of clients in the Subject Countries were
[CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION] ([CONFIDENTIAL INFORMATION HAS BEEN OMITTED
AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION]of total
Client Assets as at that date) and revenues earned from those relationships in
the nine months to 30 September 2005 were [CONFIDENTIAL INFORMATION HAS BEEN
OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION]
(being approximately [CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED
SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION] of total revenues in the
year to date).

By Subject Country, these
figures break down as follows:

_______________________________________________________________________________________________
                                          As at 31.12.2004            As at 30.09.2005
_______________________________________________________________________________________________
                                      Client Assets   Revenues     Client Assets   Revenues
_______________________________________________________________________________________________
Cuba* (see detail in section 3)
______________________________________
Iran* (see detail in section 4)
______________________________________
Libya* (see detail in section 5)
______________________________________  [CONFIDENTIAL INFORMATION HAS BEEN OMITTED
Total*                                  AND FURNISHED SEPARATELY TO THE SECURITIES
______________________________________  AND EXCHANGE COMMISSION]
% of relevant Group total**
______________________________________

__________________

1     For the purposes of this letter, the term
“Client Assets” means all client assets managed or deposited (i.e.,
held by) with UBS including custody-only assets and assets held for purely
transactional purposes. This is consistent with the definition used in the UBS
Group’s financial reporting (see page 11 of the UBS Financial Report 2004
available at http://www.ubs.com/1/e/investors/annual_reporting2004.html ,
and is a wider term than our central measure of “Invested Assets”
(meaning all client assets managed by or deposited with UBS for investment
purposes).

2 Although all figures in this letter are stated in US dollars for
the sake of consistency, this does not mean that the underlying relationships described in
this letter are conducted in or involve transactions in US dollars. Exchange rates used to
convert into US dollars were the prevailing spot rates on the relevant dates to which the
figures relate.

3 All comparisons with wider Group figures have been calculated to
two decimal places.

     CONFIDENTIAL TREATMENT REQUESTED BY UBS AG
     16 November 2005

Page 3 of 7

*= all figures in Thousand
U.S. dollars (but see footnote 2 below)

** For these comparative purposes,
total Client Assets of the UBS Group were [CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND
FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION] (as at 31 December 2004)
and were [CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE
SECURITIES AND EXCHANGE COMMISSION] (as at 30 September 2005). Total revenues of the UBS
Group in 2004 were [CONFIDENTIAL INFORMATION HAS BEEN OMITTED AND FURNISHED SEPARATELY TO
THE SECURITIES AND EXCHANGE COMMISSION] and were [CONFIDENTIAL INFORMATION HAS BEEN
OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION] in the nine
months to 30 September 2005

[CONFIDENTIAL INFORMATION
HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION]

1.    Physical Presence /
Employees in the Subject Countries

Neither UBS AG nor any of its
consolidated subsidiaries (collectively, the “Group”) have any physical presence
(branch, subsidiary, affiliate or otherwise) in any of the Subject Countries. The Group
has no employees located in any of the Subject Countries.

2.     Business Activities
involving the Subject Countries — Introduction

In the following sections, the
Subject Country Activities undertaken by the Group are described both for the year to 31
December 2004 as well as for the nine month period to 30 September 2005. We have sought to
present the information consistently for each Subject Country and to provide a brief
explanation and relevant figures in summary form.

In all cases, we would emphasize that
all Subject Country Activities mentioned in the following sections are conducted and
relationships are maintained pursuant to procedures designed to ensure that the
relationships are fully compliant with applicable law (including U.S. law if and to the
extent that it is applicable). As the Staff is aware, U.S. sanctions generally are not
legally applicable to UBS’s activities outside the United States. In all cases and
unless otherwise specified, the relationships mentioned are maintained outside the U.S.

For each Subject Country, we deal
with the following:

•

“Government relationships” – by which we refer to business relationships
(if any) with the government of the Subject Country itself as well as business
relationships with entities believed to be controlled by the Government and relationships
with any individual member of the Government in either his or her official or personal
capacity. However, we deal with relationships with banks (including government-owned
banks) in each Subject Country separately and do not therefore include them in this part
of our analysis.

•

“Bank relationships” – by which we refer to business relationships with
banks (including government owned banks) in the Subject Countries. These relationships are
maintained primarily to facilitate routine banking transactions for non-U.S. clients who
undertake transactions themselves with counterparts in the Subject Country (e.g. our
relationship with the Subject Country financial institution allows us to offer our clients
traditional banking services such as the ability to make or receive payments with
counterparts in a Subject Country).

     CONFIDENTIAL TREATMENT REQUESTED BY UBS AG
     16 November 2005

Page 4 of 7

•
“Other
Client relationships” – by which we refer to all other business
relationships we may have with parties (natural persons or legal entities) known
by us to have a business location or residence in a Subject Country. Where this
information is available to us in our systems, we have included relationships
with legal entities situated outside a Subject Country where we know the parent,
ultimate holding company or a material beneficial owner of the entity is known
to reside in a Subject Country. For the avoidance of doubt, we do not include
relationships with nationals of a Subject Country who are not resident in the
Subject Country (including e.g. exiles). The types of relationships we refer to
here may include relationships with both individuals and legal entities and may
involve the provision of individual or corporate banking services, investment
advice, securities and custody accounts, asset management services as well as
collateralised credit facilities secured against assets deposited with the Group
for the purpose of finalising additional investments in securities (i.e.
leveraging).

•
“Financing
or credit arrangements” – by which we refer to trade and export
financing (including e.g. letters of credit, confirmations of financing and
similar) issued by the Group on behalf of clients in connection with the
client’s own dealings with a Subject Country. In this context we give an
indication of total volumes of trade and export finance activity involving the
country in question in the relevant period (being for the year 2004 and for the
six months to 30 June 2005) including the level of financings where the Group
has no economic risk due to syndications or risk participations or insurance by
third parties. We also include any transactions that are only facilitated
without further obligation (i.e. where the Group has no financial involvement
other than collecting/forwarding shipping documents or facilitating transfers
via its network of correspondent banks). We also give a “net risk”
figure for the trade and export finance business as at 31 December 2004 and 30
September 2005. This “net risk” figure reflects UBS’s own
exposure (i.e. excluding exposure that is syndicated to, or participated in by,
third parties or covered by cash collateral) at the relevant date in respect of
the particular Subject Country. Credit facilities granted to clients resident in
a Subject Country for investment purposes are not included in this section
because where such facilities exist, the amounts involved are included within
the figures for “other client relationships” as described above.

In the following analysis and where
necessary we have also provided more detail on other aspects of our Subject Country
Activities where this would not otherwise be not sufficiently covered within the above
categories.

3.     Cuba

______________________________________________________________________________________________________
                                      As at 31.12.2004            As at 30.09.2005
______________________________________________________________________________________________________
                                  Client Assets   Revenues     Client Assets   Revenues
______________________________________________________________________________________________________
Government relationships*
__________________________________
Bank relationships*
__________________________________
Other Client relationships*
__________________________________  [CONFIDENTIAL INFORMATION HAS BEEN OMITTED
Total*                              AND FURNISHED SEPARATELY TO THE SECURITIES
__________________________________  AND EXCHANGE COMMISSION]
% of relevant Group total**
__________________________________
                                  Total Volume     Net Risk as    Total Volume -   Net Risk as at
                                   during 2004     at 31.12.04     6 months to        30.9.05
                                                                     30.6.05
______________________________________________________________________________________________________
Financing / Credit Arrangements*    [CONFIDENTIAL INFORMATION HAS BEEN OMITTED
                                    AND FURNISHED SEPARATELY TO THE SECURITIES
                                    AND EXCHANGE COMMISSION]
______________________________________________________________________________________________________

* = all figures in Thousand U.S.
dollars (but see footnote 2 above)

     CONFIDENTIAL TREATMENT REQUESTED BY UBS AG
     16 November 2005

Page 5 of 7

Other Points to Note
Regarding Cuba:

[CONFIDENTIAL INFORMATION
HAS BEEN OMITTED AND FURNISHED SEPARATELY TO THE SECURITIES AND EXCHANGE COMMISSION]

4.    Iran

__________________________________________________________________________________________________________
                                      As at 31.12.2004            As at 30.09.2005
______________________________________________________________________________________________________
                                  Client Assets   Revenues     Client Assets   Revenues
______________________________________________________________________________________________________
Government relationships*
__________________________________
Bank relationships*
__________________________________
Other Client relationships*
__________________________________  [CO