P.O. Box 2600
Valley Forge, PA 19482-2600
Cassandre_Juste@vanguard.com
September 14, 2020
Lisa N. Larkin, Esq.
U.S. Securities and Exchange Commissionvia electronic filing
100 F Street, N.E.
Washington, DC 20549
RE:Vanguard World Fund (the “Trust”)
File No. 2-17620
Post-Effective Amendment No. 167
Dear Ms. Larkin,
This letter responds to your comments provided on August 26, 2020, on the above referenced post-effective amendment. The comments apply to Vanguard ESG U.S. Corporate Bond ETF, a series of the Trust (the “Fund”).
Comment 1: | Principal Investment Strategies |
Comment: | Please provide more information on what is meant by companies “involved in and/or derive threshold amounts of revenue from certain activities.” |
Response: | The disclosure has been revised accordingly. |
Comment 2: Principal Investment Strategies
Comment: | Please explain how the index methodology defines “controversial weapons” and “conventional weapons”. |
Response: | The disclosure refers shareholders to the “Security Selection” section of the prospectus, which defines these terms. |
Comment 3: | Principal Investment Strategies |
Comment: | Please provide more information on the index provider’s ESG controversies assessment. |
Response: | The disclosure has been revised accordingly. |
Comment 4: |
Principal Investment Strategies |
Comment: | Please clarify how companies that do not report board diversity are assessed under the index methodology. |
Response: | The disclosure has been revised accordingly. |
Comment 5: | Principal Risks |
Comment: | “Interest rate risk” mentions intermediate-term bonds. Please clarify how intermediate bonds will be used in the ETF. |
Response: | The disclosure has been revised accordingly. |
Comment 6: | Principal Risks |
Comment: | To the extent they are considered principal risks, please add “concentration risk” and “tracking risk” to the principal risks section. |
Response: | The disclosure has been revised accordingly. |
Comment 7: | Security Selection |
Comment: | Please state the name of the index provider. |
Response: | The disclosure has been revised accordingly. |
Comment 8: | Security Selection |
Comment: | Please state the approximate number of index constituents in the target index. |
Response: | The disclosure has been revised accordingly. |
Please contact me at cassandre_juste@vanguard.com with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Cassandre L. Juste
Cassandre L. Juste
Associate Counsel
The Vanguard Group, Inc.