P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-7310
Lex_Smith@vanguard.com
September 12, 2013
Alberto H. Zapata, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Variable Insurance Funds; File No. 33-32216
Dear Mr. Zapata,
The following responds to our conversation on September 12, 2013 on the post-effective amendment of the registration statement of the above-referenced registrant. You commented on Post-Effective Amendment No. 69 that was filed on August 1, 2013 pursuant to Rule 485(a).
Comment 1: Tandy Requirements
As required by the SEC, the Funds acknowledge that:
· Each 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.
· Each 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) 669-7310 with any questions or comments regarding the above response. Thank you.
Sincerely,
Alexander F. Smith
Associate Counsel