P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2689
Lisa_l_matson@vanguard.com
September 27, 2011
Chad Eskildsen, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard STAR Funds
Dear Mr. Eskildsen:
The following responds to Brion Thompson’s comments of September 12, 2011 on the post-effective amendment of the above-referenced registrant (the “Trust”) and its series, Vanguard Developed Markets Index Fund (the “Fund”). Mr. Thompson commented on Post-Effective Amendment No. 63, which was filed on July 25, 2011 pursuant to Rule 485(a).
Comment 1: Prospectus – Fund Summary – Fees and Expenses
Comment: The fee table shows both Investor Shares and Admiral Shares while the prospectus offers only Admiral Shares.
Response: We will update the fee table to show only Admiral Shares.
Comment 2: Prospectus – Fund Summary – Fees and Expenses
Comment: The figures for Management Expenses are different between Investor Shares and Admiral Shares. Confirm that the advisory fee is the same for each share class.
Response: The advisory fee allocated to each share class is the same.
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) 669-5284 with any questions or comments regarding the above responses and explanations.
Sincerely,
Lisa L. B. Matson
Associate Counsel
The Vanguard Group, Inc.
cc: Brion Thompson, Esq.