SHIP LOGO VANGUARD(R)
P.O. BOX 2600
VALLEY FORGE, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
September 6, 2006
Christian Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission via electronic filing
450 Fifth Street,
N.W., Fifth Floor
Washington, D.C. 20549
RE: Vanguard Quantitative Funds
Dear Mr. Sandoe,
The following responds to your comments of August 29, 2006 on the
post-effective amendment of the registration statement of the above-referenced
registrant. You commented on Post-Effective Amendment No. 27 that was filed on
July 5, 2006.
Comment 1: Prospectus - Primary Investment Strategies
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Comment: Include a reference to any market capitalization strategy
employed by the Fund, and include the market capitalization as
of a recent date.
Response: The Fund does not have a primary investment strategy of
investing in any particular market capitalization, so we do
not plan to include anything in the Item 2 disclosure.
However, we will include the market capitalization range of
the Fund's target index as of a recent date in our Item 4
disclosure.
Comment 2: Prospectus - Performance/Risk Information
- -----------------------------------------------------------
Comment: Revise the second sentence of footnote 1 so it is clear
whether the Fund's Portfolio Manager served in this capacity
for both the Fund and the collective trust that preceded it.
Response: We will make the requested edit so it is clear that the same
PM has managed the Fund's assets dating back to the inception
date of the collective trust that preceded the Fund.
Comment 3: Prospectus - Plain Talk About the Fund's Portfolio Manager
- ----------------------------------------------------------------------------
Comment: Please clarify whether the PM has managed the Fund and the
collective trust since the inception of each.
Christian Sandoe, Esq.
September 6, 2006
Page 2
Response: The PM has managed both the collective trust and the Fund
since inception so we will modify our disclosure to make
this more clear.
Comment 4: Tandy Requirements
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As required by the SEC, the Fund acknowledges that:
o The Fund is responsible for the adequacy and accuracy of the
disclosure in the filing.
o 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.
o 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) 669-1538 with any questions or comments
regarding the above responses. Thank you.
Sincerely,
Judith L. Gaines
Associate Counsel
Securities Regulation, Legal Department