February 1, 2019 | |
Lisa N. Larkin, Esq. | |
U.S. Securities and Exchange Commission | via electronic filing |
100 F Street, N.E. | |
Washington, DC 20549 | |
RE:Vanguard Bond Index Funds | |
File No. 33-06001 | |
Post-Effective Amendment No. 81 | |
Vanguard International Equity Index Funds | |
File No. 33-32548 | |
Post-Effective Amendment No. 117 | |
Vanguard Whitehall Funds | |
File No. 33-64845 | |
Post-Effective Amendment No. 78 | |
Vanguard World Fund | |
File No. 2-17620 | |
Post-Effective Amendment No. 159 |
Dear Ms. Larkin, |
This letter responds to your comments provided via telephone on January 28, 2019, on the above- |
referenced post-effective amendments. The comments apply to the Admiral share class for each of the |
following: Vanguard Long-Term Bond Index Fund, a series of Vanguard Bond Index Funds; |
Vanguard FTSE All-World ex-US Small-Cap Index Fund, a series of Vanguard International Equity |
Index Funds; Vanguard Total World Stock Index Fund, a series of Vanguard International Equity |
Index Funds; Vanguard High Dividend Yield Index Fund, a series of Vanguard Whitehall Funds; and |
Vanguard FTSE Social Index Fund, a series of Vanguard World Fund (each, a “Fund” and together, |
the “Funds”). |
Comment 1: | All Funds – Prospectus – Fee Table (Annual Fund Operating Expenses) |
Comment: | Each Fund’s fee table includes a footnote stating “The expense information |
shown in the table reflects estimated amounts for the current fiscal year.” Please | |
explain supplementally the basis for estimating amounts. |
Lisa Larkin, Esq. | |
February 1, 2019 | |
Page 2 | |
Response: | The Funds’ Admiral Shares have not yet commenced operations. Therefore, the |
expense information shown in each Fund’s prospectus reflects estimated amounts | |
for the current fiscal year. | |
Comment 2: | All Funds – Prospectus – Fee Table (Example) |
Comment: | Each Fund’s prospectus includes hypothetical expenses for 1- and 3-year periods. |
Please add hypothetical expenses for 5- and 10-year periods. | |
Response: | We will make this requested change. |
Please contact me at (610) 669-7310 with any questions or comments regarding the above | |
responses. Thank you. | |
Sincerely, |
Alexander F. Smith
Associate Counsel
The Vanguard Group, Inc.