P.O. Box 2600 | ||
Valley Forge, PA 19482-2600 | ||
610-669-1955 | ||
tara_r_buckley@vanguard.com | ||
January 30, 2012 | ||
Brion Thompson, Esq. | ||
U.S. Securities & Exchange Commission | via electronic filing | |
100 F Street, N.E. | ||
Washington, DC 20549 | ||
RE: | Vanguard Fixed Income Securities Funds; File No. 2-47371 |
Dear Mr. Thompson:
The following responds to your comments of December 20, 2011 on the post-effective amendment of the above-referenced registrant. You commented on Post-Effective Amendment No. 91, which was filed on November 22, 2011 pursuant to Rule 485(a).
Comment 1: | Short-Term Treasury Fund – Prospectus – Primary Investment |
Strategies | |
Comment: | The Primary Investment Strategies section states that the dollar-weighted |
average maturity for the Fund will be 1-4 years. The staff takes the | |
position that the average maturity for a short-term fund is 1-3 years. | |
Response: | The adopting release for rule 35d-1 states that the purpose of the rule is to |
prevent investment companies from adopting names that could mislead | |
investors about a fund’s investments and risks. In the adopting release, the | |
SEC provided guidance that the dollar-weighted average maturity for a | |
short-term bond fund should not exceed 3 years. The text of the rule, | |
however, does not require a 3-year maturity for short-term funds. We | |
believe that under any reasonable interpretation of the adopting release | |
and rule 35d-1, a dollar-weighted average maturity range of 1- 4 years | |
qualifies as “short-term.” For these reasons, we believe that the names of | |
the Vanguard Short-Term Treasury, Short-Term Federal and Short-Term | |
Investment Grade Funds are not misleading. | |
Comment 2: | Long-Term Investment-Grade Fund – Prospectus – Primary |
Investment Strategies | |
Comment: | Add disclosure to the Primary Investment Strategies section identifying |
the dollar-weighted average maturity of the fund’s benchmark index. | |
Response: | We have added the requested disclosure. |
0234567
Brion Thompson, Esq.
January 30, 2012
Page 2
Tandy Requirements
As required by the SEC, each Fund acknowledges that:
• | The Fund is responsible for the adequacy and accuracy of the |
disclosure in the filing. | |
• | Staff comments or changes in response to staff comments in the filings |
reviewed by the staff do not foreclose the Commission from taking | |
any action with respect to the filing. | |
• | The Fund 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. |
Please contact me at (610) 669-1955 with any questions or comments regarding the above responses and explanations.
Sincerely,
Tara R. Buckley
Senior Counsel
The Vanguard Group, Inc.