September 30, 2020 |
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Lisa Larkin, Esq. |
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U.S. Securities & Exchange Commission | via electronic filing | |
100 F Street, N.E. |
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Washington, DC 20549 |
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RE: | Vanguard Specialized Funds; File Nos. 2-88116; 811-03916 | |
| Vanguard World Fund; File Nos. 2-17620; 811-01027 | |
| Vanguard Variable Insurance Funds; File Nos. 33-32216; 811-05962 | |
| (the "Vanguard Funds") |
|
Dear Ms. Larkin,
This letter responds to your comments provided on September 28, 2020 regarding the Vanguard Funds' Preliminary Proxy Statement filed on September 17, 2020.
Comment 1: | On March 13, 2020, the SEC issued guidance on conducting virtual shareholder meetings (see Staff |
| Guidance for Conducting Shareholder Meetings in Light of COVID-19 Concerns). Please confirm |
| awareness of such guidance as the Vanguard Funds prepare to host a virtual shareholder meeting. |
Response: | We confirm that the Vanguard Funds are aware of, and will continue to rely on, the SEC's guidance |
Comment 2: | on conducting virtual shareholder meetings. |
If the Vanguard Funds do not successfully obtain shareholder approval to change their | |
| diversification status under the Investment Company Act of 1940 (the "1940 Act"), then have the |
| investment advisors and the Boards of Trustees considered changing the Vanguard Funds' |
| investment strategies as they would continue to operate as diversified funds? If so, please provide |
| an analysis on the intended changes to the investment strategies. |
Response: | The investment advisors and Boards of Trustees for the Vanguard Funds have not considered |
| changing the investment strategies for any of the Vanguard Funds if shareholder approval is not |
| obtained. Therefore, the investment advisors would continue to manage the Vanguard Funds in |
| accordance with the diversification rules under the 1940 Act and the related fundamental policy. |
Please contact me at mary_salvucci@vanguard.com with any questions or comments regarding the above responses.
Sincerely,
/s/ Mary Salvucci Mary Salvucci Associate Counsel
The Vanguard Group, Inc.
