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.