SHIP LOGO VANGUARD(R)
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
December 20, 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 December 18, 2006 on the
post-effective amendment of the registration statement of the above-referenced
registrant. You commented on Post-Effective Amendment No. 31 that was filed on
November 1, 2006.
Comment 1: Prospectus - Risk/Return Summary
- --------------------------------------------------
Comment: Include the Structured Large-Cap Value Fund's policy of
investing at least 80% of its assets in large-cap stocks in
the risk/return summary.
Response: While the Fund does have such a policy, we do not plan to
include related disclosure in the risk/return summary. Since
that placement is not required by Form N-1A, we prefer to keep
the 80% policy in our Item 4 disclosure.
Comment 2: Prospectus - Performance/Risk Information
- -----------------------------------------------------------
Comment: Clarify that performance information for the Structured Large
Cap Value Fund's predecessor trust isn't available for a full
calendar year given its January 19, 2006 inception date.
Response: As I noted on the phone, the inception date for the
predecessor trust is actually December 15, 2005, so we will
present a full calendar year of performance in the Fund's Item
2 disclosure.
Comment 3: SAI - Investment Limitations
- ----------------------------------------------
Comment: In this section of the SAI, please clarify that while the SAI
states that compliance with investment limitations is measured
at the time securities are purchased, compliance with the
borrowing limitation is measured on an ongoing basis.
Christian Sandoe, Esq.
December 20, 2006
Page 2
Response: We will make the requested modification.
Comment 4: Prospectus and SAI - Throughout the N-1A
- ----------------------------------------------------------
Comment: Include updated financial information for the registrant's
existing series as necessary.
Response: We will include updated financial information as necessary.
Comment 5: Tandy Requirements
- ------------------------------------
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