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[email protected] August 10, 2021 Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Substituted Compliance Application for Swiss Bank Security-Based Swap Dealers from Certain Requirements under Exchange Act Section 15F and Regulations Thereunder Dear Ms. Countryman: We are submitting this application on behalf of UBS AG and Credit Suisse AG to request that the Securities and Exchange Commission (“Commission” or “SEC”) make a determination with respect to the risk control, recordkeeping and reporting, and internal supervision and compliance requirements under Swiss law specified herein that compliance with these Swiss law requirements by systemically important banks organized in Switzerland and subject to the oversight of the Swiss Financial Market Supervisory Authority (“FINMA”) satisfies the analogous requirements applicable to a security-based swap dealer (“SBSD”) that has a Prudential Regulator under Sections 15F of the Securities Exchange Act of 1934 (“Exchange Act”) and regulations thereunder. While the substance of the enclosed application would be relevant for all Swiss firms meeting the above criteria, it is tailored to the activities of UBS AG and Credit Suisse AG. We would note in this regard that we are not requesting substituted compliance for certain SBSD obligations owing to the fact that both UBS AG and Credit Suisse AG have a Prudential Regulator as defined by the Exchange Act. The enclosed application proceeds in four sections, with each section responsive to one or more of the elements of a substituted compliance application described in the Commission staff’s guidance, Elements of an Application for Substituted Compliance for Foreign Security-Based Swap Dealers and Major Security-Based Swap Participants:1 Section I responds to element one of the staff’s guidance by describing the scope of this substituted compliance request.