P.O. Box 2600 | |||
Valley Forge, PA 19482-2600 | |||
610-669-1538 | |||
judy_l_gaines@vanguard.com | |||
April 10, 2014 | |||
Amy Miller, 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 Ms. Miller, | |||
This letter responds to your comments provided by telephone on April 9, 2014 on the | |||
post-effective amendment of the above-referenced registrant. You commented on Post-Effective | |||
Amendment No. 134 that was filed on February 21, 2014 in order to add Ballie Gifford Overseas Ltd. | |||
and Jennison Associates LLC as advisors to Vanguard U.S. Growth Fund (the “Fund”), a series of | |||
the Trust. | |||
Comment 1: | Prospectus – Fund Summary– Investment Advisor(page 4) | ||
Comment: | Please include an introductory sentence prior to the listed portfolio managers to | ||
clarify that the listed individuals are jointly and primarily responsible for the day- | |||
to-day management of the Fund’s portfolio. | |||
Response: | We have considered the comment and do not plan to make any changes to the | ||
portfolio manager disclosure. We believe the presentation is compliant with Form | |||
N-1A, Item 5(b). | |||
Comment 2: | Prospectus – Fund Summary – Tax Information (page 5) | ||
Comment: | As currently drafted, the prospectus states that “The Fund’s distributions may be | ||
taxable as ordinary income or capital gain. If you are investing through a tax- | |||
deferred retirement account, such as an IRA, special tax rules apply.” Please be | |||
more specific regarding the referenced special tax rules. | |||
Response: | We have considered the comment and do not plan to edit the existing disclosure. | ||
We believe the existing disclosure is compliant with Form N-1A, Item 7. As we | |||
mentioned in our phone conversation, the tax rules for these types of accounts are | |||
complex and vary. We disclose farther back in the statutory prospectus, in | |||
response to Item 11(f) of Form N-1A, that clients investing through tax-deferred | |||
retirement accounts, such as an IRA, should consult with their tax advisor for | |||
detailed information regarding tax consequences. Additionally, different | |||
language appears in the Tax Information section of the Fund Summary for the | |||
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prospectuses that are designed specifically for the participants in employer- | |
sponsored retirement plans. | |
Comment 3: | Prospectus – Primary –vs- Principal (pages 2 and 6) |
Comment: | In order to more closely conform to Item 4 of Form N-1A, please use the word |
“principal” rather than “primary” when discussing the investment strategy and | |
risks of the Fund. | |
Response: | We will make the requested edit. |
Comment 4: | Prospectus – More on the Fund–Other Investment Policies and Risks (page |
11) | |
Comment: | Please confirm whether the investment strategies and policies discussed in the |
“Other Investment Policies and Risks” section of the prospectus are non-principal | |
Fund strategies and policies. | |
Response: | We confirm that the strategies and policies disclosed in the “Other Investment |
Policies and Risks” are not principal strategies and policies of the Fund. | |
Comment 5: | Prospectus – More on the Fund – Investment Advisors (page 16) |
Comment: | Please provide more detail regarding Ian Tabberer’s business experience during |
the past five years. | |
Response: | We have considered the comment and do not plan to make any changes to the |
description of the named portfolio managers. We believe the level of detail | |
provided meets the standard of Form N-1A, Item 10(a)(2). | |
Comment 6: | SAI – Fundamental Policies – Industry Concentration |
Comment: | The concentration policy does not specify that the SEC staff takes the position |
that a fund concentrates its investments if it invests more than 25% of its assets in | |
any particular industry. Please add this disclosure. | |
Response: | We will add the requested disclosure to the investment strategies and |
nonfundamental policies section of the SAI. We include detail regarding certain | |
of our fundamental policies in this section, so this placement is consistent with | |
where we currently include details of our borrowing policy, commodities policies, | |
and so on. | |
Comment 7: | Part C – Exhibits – Item 28(d) |
Comment: | Please add the Investment Advisory Contracts for Ballie Gifford Overseas Ltd. |
and Jennison Associates LLC as exhibits to the registration statement. | |
Response: | The Investment Advisory Contracts for Ballie Gifford Overseas Ltd. and Jennison |
Associates LLC will be filed as exhibits to the registration statement on April 22, | |
2014. |
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Comment 8: | Part C – Business and Other Connections of Investment Adviser |
Comment: | Please provide information on Jennison Associates, LLC in response to Item 31. |
Response: | We will add the requested information. |
Comment 9: | 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 response. Thank you. | |
Sincerely, | |
Judith L. Gaines | |
Associate Counsel |
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