P.O. Box 2600, Mail Stop V26
Valley Forge, PA 19482-2600
610-503-2398
barry_mendelson @vanguard.com
April 26, 2013
Amy Miller, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Malvern Funds (the “Trust”)
Registration Statement No. 33-23444
Post-Effective Amendment No. 55
Dear Ms. Miller,
This letter responds to your comments provided on March 28, 2013 on the above-referenced post-effective amendment, which seeks to register shares of Vanguard TIPS Transition Fund (the “Fund”), a new series of the trust.
Comment 1: Prospectus – Investment Advisor (page 12)
Comment: Provide more detail regarding the portfolio managers’ 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, other than to note the year Ms. Wright-Casparius began working at Vanguard. As modified, we believe the level of detail provided meets the standard of Form N-1A, Item 10(a)(2).
Comment 2: SAI – Industry Concentration Policy (pages B11-12)
Comment: Include an industry concentration policy for the Fund.
Response: We have made the requested change.
0289336, 0.1
Amy Miller, Esq.
April 26, 2013
Page 2
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) 503-2398 with any questions or comments regarding this letter or the Trust’s filing. Thank you.
Sincerely,
Barry A. Mendelson
Principal and Senior Counsel