P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2531
Elizabeth_Bestoso@vanguard.com
September 23, 2019 | ||
Lisa N. Larkin, Esq. | ||
U.S. Securities and Exchange Commission | via electronic filing | |
100 F Street, N.E. | ||
Washington, DC 20549 | ||
RE: Vanguard Horizon Funds (the “Trust”) | ||
File No. 33-56443 | ||
Post-Effective Amendment No. 63 – Vanguard International Core Stock Fund (the “Fund”) | ||
Dear Ms. Larkin, | ||
This letter responds to your comments provided on August 22, 2019, to the above referenced post- | ||
effective amendment. | ||
Comment 1: | Principal Investment Strategies | |
Comment: | In the “Principal Investment Strategies” section, please confirm that the Fund will invest | |
at least 40% of its assets in the stocks of companies located outside the U.S. | ||
Response: | We confirm that the Fund will invest at least 40% of its assets in the stocks of companies | |
located outside the U.S. | ||
Comment 2: | Principal Investment Strategies | |
Comment: | Per Rule 35d-1 under the 1940 Act, please add an 80% policy of investing in stocks. | |
Please also add a statement that the Fund will provide shareholders with 60 days notice if | ||
there is a change to such 80% policy. | ||
Response: | We have revised the disclosure in the manner requested. | |
Comment 3: | Market Exposure | |
Comment: | In the “Market Exposure” section, please reconcile the statement that the Fund invests | |
“without regard to size (capitalization) of the companies” with the earlier statement under | ||
the “Principal Investment Strategies” section that the advisor “chooses large- and mid- | ||
capitalization companies.” | ||
Response: | We have revised the disclosure in the manner requested. | |
Comment 4: | Securities Selection | |
Comment: | Under the “Securities Selection” section, please do not use the phrases “systematically | |
leverages” in the first sentence and “alpha potential” in the last sentence. |
Lisa N. Larkin, Esq.
September 23, 2019
Page 2
Response: | We have revised the disclosure in the manner requested. |
Comment 5: | Other Investment Policies and Risks |
Comment: | The Staff notes that in the “Other Investment Policies and Risks” section, the first |
sentence states that the Fund “may make other kinds of investments to achieve its | |
objectives.” Please confirm that such “other kinds of investments” are those described in | |
the immediately following paragraphs. | |
Response: | We confirm that the “other kinds of investments” referenced in the first sentence of the |
“Other Investment Policies and Risks” section are those described in the immediately | |
following paragraphs. | |
Comment 6: | Other Investment Policies and Risks |
Comment: | The Staff notes that the Fund invests in convertible securities. If the Fund expects to |
invest in contingent convertible securities (“CoCos”), please consider what, if any, | |
disclosure is appropriate. The type and location of disclosure will depend on, among | |
other things, the extent to which the Fund invests in CoCos, and the characteristics of the | |
CoCos (e.g., the credit quality and the conversion triggers). If CoCos will be a principal | |
type of investment, the Fund should provide a description of them and should provide | |
appropriate risk disclosure. Please tell us supplementally the amount the Fund intends to | |
invest in CoCos. | |
Response: | The Fund does not expect to invest in CoCos. |
Comment 7: | Other Investment Policies and Risks |
Comment: | Per Item 9(b)(2) of Form N-1A, please add disclosure explaining how the advisor |
determines which securities to sell. | |
Response: | While we believe the existing disclosure conforms with Item 9(b)(2), we have revised the |
disclosure in the manner requested. | |
Comment 8: | Statement of Additional Information |
Comment: | Per Item 16(c)(1)(iv) of Form N-1A, please add “or group of industries” to the end of the |
sentence in the sub-section titled “Industry Concentration.” | |
Response: | We have revised the disclosure in the manner requested. |
Lisa N. Larkin, Esq.
September 23, 2019
Page 3
Please contact me at (610) 669-2531 with any questions or comments regarding the above response.
Thank you.
Sincerely,
/s/ Elizabeth Bestoso
Elizabeth Bestoso
Associate Counsel
The Vanguard Group, Inc.