P.O. Box 2600
Valley Forge, PA 19482-2600
484-618-9535
laura_bautista@vanguard.com
December 15, 2017
Lisa N. Larkin, Esq.
U.S. Securities and Exchange Commission | via electronic filing |
100 F Street, NE |
Washington, DC 20549
RE: | Vanguard Scottsdale Funds (the “Trust”) |
File No. 333-11763 | |
Post-Effective Amendment No. 48 – Vanguard Short-Term Treasury Index Fund, Vanguard | |
Intermediate-Term Treasury Index Fund, and Vanguard Long-Term Treasury Index Fund | |
(collectively, the “Funds”) |
Dear Ms. Larkin,
This letter responds to your comments provided to us by telephone on December 5, 2017, with respect to the above-referenced post-effective amendment to the Funds’ registration statement.
Comment: | Prospectuses |
Comment: | To the extent not already disclosed, please add disclosure to the Funds’ prospectuses |
regarding (a) the index rebalance and reconstitution process, including the frequency | |
thereof, (b) an explanation of how and when the indices change, and (c) the number of | |
index components. | |
Response: | Current disclosure set out in the Funds’ prospectuses under the heading “Security |
Selection” identifies the number of bonds included in each Fund’s target index. |
The following disclosure has been added to the Funds’ prospectuses under the heading “Security Selection”:
The components of the target indices of Vanguard Short-Term Treasury Index Fund, Vanguard Intermediate-Term Treasury Index Fund, and Vanguard Long-Term Treasury Index Fund are reconstituted and rebalanced on a monthly basis. Each index rebalances as a float-adjusted market-weighted index, and bonds may enter or fall out of the index on a monthly basis. New securities are added to and removed from an index in connection with the month-end index rebalance process.
Please contact me at (484) 618-9535 with any questions or comments regarding the above response.
Thank you.
Sincerely,
/s/ Laura A. BautistaLaura A. Bautista Associate Counsel The Vanguard Group, Inc.