December 24, 2015 | ||
Asen Parachkevov, Esq. | ||
U.S. Securities and Exchange Commission | via electronic filing | |
100 F Street, N.E. | ||
Washington, DC 20549 | ||
RE: | Vanguard International Equity Index Funds (the “Trust”) | |
File No. 33-32548 | ||
Post-Effective Amendment Number 103 |
Dear Mr. Parachkevov,
This letter responds to your comments provided on December 18, 2015, on the above referenced post-effective amendment. The comments apply to Vanguard European Stock Index Fund, Vanguard Pacific Stock Index Fund, and Vanguard Emerging Markets Stock Index Fund.
Comment 1: | Prospectus |
Comment: | Please confirm that the subsequent post-effective amendment will include |
conforming content changes for all share classes offered by each Fund as | |
this post-effective amendment only included Investor Shares and Admiral | |
Shares. | |
Response: | The updated prospectuses for the other share classes of each Fund will be |
included in a 485(b) filing prior to the effective date. | |
Comment 2: | Prospectus – Fund Summary |
Comment: | Pursuant to Item 4 of Form N-1A, please consider including information |
about the spliced index in the narrative explanation accompanying the bar | |
chart and table for each Fund. | |
Response: | In response to staff comments received in August 2010, the definition of the |
spliced index was removed from the Item 4 disclosure. In response to your | |
comments, we will restore these descriptions as responsive to Item 4, | |
Instruction 2 (b) in the subsequent post-effective amendment. | |
Comment 3: | Prospectus – Vanguard Emerging Markets Stock Index Fund |
Comment: | Please provide the rationale for using a transition index for the Fund rather than |
moving right to the new target benchmark. |
Response: | As described in the initial notice and prospectus supplement, the Fund’s Board |
approved the use of a transition index in order to enable the Emerging Markets | |
Stock Index Fund’s advisor, The Vanguard Group, Inc., to make the necessary | |
adjustments to portfolio holdings in a manner that minimizes impact to Fund | |
shareholders. The transition index will gradually increase exposure to China A- | |
shares and small-capitalization equity securities while proportionately reducing | |
exposure to other stocks based on their weightings in the new target index. | |
Comment 4: | Prospectus – More on the Fund |
Comment: | Please confirm that the derivatives investments listed in this section are not |
part of the Funds’ principal investment strategies. | |
Response: | We have reviewed the disclosure and can confirm that derivatives investments |
are not part of the Funds’ principal investment strategies. | |
Comment 5: | SAI – China A-shares Risk |
Comment: | Please confirm that you have considered the appropriate disclosure of the risks |
associated with the recent market events in China when trading was halted by | |
numerous China A-shares issuers. | |
Response: | We considered the risks associated with the recent market events and |
determined that because this risk is generally heightened in other foreign | |
markets, not only in China, it is appropriately disclosed in the description of | |
Foreign Securities. Additionally, given the percentage of China A-shares | |
included in the new target benchmark (approximately 6% as of September 30, | |
2015) it was determined that this and other settlement risks unique to China A- | |
shares are appropriately disclosed in the statement of additional information. | |
Comment 6: | Tandy Requirements |
As required by the SEC, each 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) 669-8439 with any questions or comments regarding the above response. Thank you.
Sincerely,
Christyn L. Rossman
Associate Counsel
The Vanguard Group, Inc.