P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1605
seth_ruderman@vanguard.com
| February 20, 2018 | |
| Lisa N. Larkin, Esq. | |
| U.S. Securities and Exchange Commission | via electronic filing |
| 100 F Street, N.E. | |
| Washington, DC 20549 | |
| RE: | Vanguard Trustees’ Equity Fund (the “Trust”) |
| File No. 811-02968 | |
| Post-Effective Amendment No. 81 – Vanguard Alternative Strategies Fund (the “Fund”) |
Dear Ms. Larkin,
This letter responds to your comments provided on February 8, 2018, on the above referenced post-effective amendment.
| Comment 1: | Principal Investment Strategies – Equity Index Futures |
| Comment: | Please confirm how much of the portfolio is expected to be allocated to equity index |
| futures. | |
| Response: | The Fund is expected to allocate its assets evenly among the six investment mandates, |
| which would result in an allocation of approximately 17% of the Fund’s assets to equity | |
| index futures. That said, as stated in the prospectus, the adviser may increase or decrease | |
| a strategy’s weighting in the Fund to a level deemed appropriate to further the Fund’s | |
| investment objective. | |
| Comment 2: | Principal Risks – Stock Market Risk |
| Comment: | Please correct the paragraph in the 485(b) filing as it appears to be cut off in the EDGAR |
| version. | |
| Response: | We have corrected the text for the typeset prospectus. |
| Comment 3: | Investing With Vanguard – Account Service Fee |
| Comment: | Please correct the sentence referring to employer-sponsored retirement plans in the |
| 485(b) filing as it appears to be cut off in the EDGAR version. | |
| Response: | We have corrected the text for the typeset prospectus. |
| Lisa N. Larkin, Esq. |
| February 20, 2018 |
| Page 2 |
| Comment 4: | Related Performance |
| Comment: | Please confirm that the prospectus includes all accounts that are substantially similar to |
| the Fund (“Related Accounts”). | |
| Response: | We confirm that the Fund’s prospectus includes all Related Accounts. |
| Comment 5: | Related Performance |
| Comment: | Please add the following statement to the end of the first paragraph: “which, if applicable, |
| may have adversely affected performance results.” | |
| Response: | We will add the requested disclosure. |
| Comment 6: | Related Performance |
| Comment: | Please confirm that the expense ratio of the Related Account is equal to or higher than the |
| expense ratio of the Fund. | |
| Response: | We have confirmed that the expense ratio of the Related Account is higher than the |
| expense ratio of the Fund. | |
| Comment 7: | Related Performance |
| Comment: | Unlike the Related Account, please confirm that the Fund’s fees and expenses include |
| custodial fees. | |
| Response: | We confirm that that Fund’s fees and expenses include custodial fees. |
| Comment 8: | Related Performance |
| Comment: | Unlike the Related Account, please confirm that the Fund has records necessary to |
| comply with Rule 204-2(a)(16) of the Investment Advisers Act of 1940 (the “Advisers | |
| Act”). | |
| Response: | We confirm that the Fund maintains the records necessary to comply with Rule 204- |
| 2(a)(16) of the Advisers Act. | |
Please contact me at (610) 669-8005 with any questions or comments regarding the above response.
Thank you.
Sincerely,
Seth Ruderman
Senior Counsel
The Vanguard Group, Inc.