P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
September 17, 2010
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard World Fund; File No. 2-17620
Dear Mr. Sandoe,
The following responds to your comments of September 15, 2010 on the post-effective amendment of the registration statement of the above-referenced registrant. You commented on Post-Effective Amendment No. 114 that was filed on July 30, 2010 pursuant to Rule 485(a). The comments pertain to Vanguard Extended Duration Treasury Index Fund.
Comment 1: Fees and Expenses
Comment: Delete the footnote to the fee table that describes the application of the purchase fee. This information is not permitted by Form N-1A in the summary section.
Response: We will delete the footnote.
Comment 2: Primary Risks
Comment: Clarify that interest rate risk is higher for zero-coupon long-term bonds than it is for coupon bearing bonds of similar maturity.
Response: We will add the requested clarification.
Comment 3: Other Investment Policies and Risks
Comment: If derivative risk is a principal risk of the Fund, make disclosure changes as noted in the SEC’s July 30, 2010 letter to the ICI.
Response: Derivative risk is not a principal risk of the Fund.
Comment 4: SAI– Fundamental Policies
Comment: The second to last paragraph of the fundamental policies section states that “unless otherwise required by the 1940 Act, if a percentage restriction is adhered to at the time the investment is made, a later change in the percentage resulting from a change in the market value of assets will not constitute a violation of the restriction.” Please modify the disclosure to note that a fund’s borrowing is an exception to the general rule stated above.
Christian Sandoe, Esq.
September 17, 2010
Page 2
Response: We have modified the disclosure as requested.
Comment 5: 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 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) 669-1538 with any questions or comments regarding the above responses. Thank you.
Sincerely,
Judith L. Gaines
Associate Counsel