P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-7310
lex_smith@vanguard.com
April 20, 2015 | ||
Asen Parachkevov, Esq. | ||
U.S. Securities and Exchange Commission | via electronic filing | |
100 F Street, N.E. | ||
Washington, DC 20549 | ||
RE: | Vanguard Index Funds (the “Trust”); | |
File No. 2-56846 | ||
Post-Effective Amendment No. 141 – Vanguard Total Stock Market Index Fund (the | ||
“Fund”) |
Dear Mr. Parachkevov,
This letter responds to your comments provided on April 14, 2015, on the above referenced post-effective amendment.
Comment 1: | Prospectus - Fund Summary – Fees and Expenses | ||||
Comment: | Please include the Fund’s complete fee table in your response letter. | ||||
Response: | Please see the fee table below. | ||||
Annual Fund Operating Expenses | |||||
(Expenses that you pay each year as a percentage of the value of your investment) | |||||
Institutional Shares | Institutional Plus Shares | ||||
Management Fees | 0.02 | % | 0.00 | % | |
12b-1 Distribution Fee | None | None | |||
Other Expenses | 0.02 | % | 0.02 | % | |
Total Annual Fund Operating Expenses | 0.04 | % | 0.02 | % | |
Comment 2: | Prospectus - Fund Summary – Tax Information | ||||
Comment: | Please clarify that withdrawals from tax-deferred retirement accounts may be subject to | ||||
taxes. | |||||
Response: | We have considered the comment and do not plan to modify the disclosure. We believe | ||||
the current disclosure appropriately conforms to the requirements of Item 7 of Form N- | |||||
1A. |
Asen Parachkevov, Esq.
April 20, 2015
Page 2
Comment 3: Tandy Requirements |
As required by the SEC, the 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 staffdo 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 theCommission or any person under the federal securities laws of the United States.
Please contact me at (610) 669-7310 with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Alexander F. Smith
Alexander F. Smith
Associate Counsel
The Vanguard Group, Inc.