[SHIP LOGO] [VANGUARD(R) LOGO]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
June 11, 2007
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission VIA ELECTRONIC FILING
100 F Street, N.E.
Washington, DC 20549
RE: VANGUARD CONVERTIBLE SECURITIES FUND
FILE NO. 33-4424
Dear Mr. Sandoe,
The following responds to comments forwarded by Brion Thompson
regarding Post-Effective Amendment No. 36 that was filed on April 26, 2007.
COMMENT: PROSPECTUS - PLAIN PRIMARY INVESTMENT STRATEGIES
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Comment: Please provide the basis for considering "debt securities with
warrants or common stocks attached" to be convertible securities.
Response: Convertible securities are not limited to "convertible bonds."
Warrants are a type of security, usually issued together with
a bond or preferred stock, which entitle the holder to buy a
proportionate amount of stock at a specified price, which is
usually higher than the market price at the time of issuance,
for a period of years or to perpetuity. A warrant is often
referred to as a "sweetener," to enhance the marketability of
the accompanying fixed income security. Warrants, when
combined with a bond or preferred stock, resemble a
convertible bond.
COMMENT: SAI - MATERIAL CONFLICTS OF INTEREST
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Comment: The current disclosure explains how the advisor seeks to prevent
material conflicts of interest. Please include some disclosure
explaining what the potential conflicts are or might be.
Response: Our existing disclosure explains that managing multiple accounts
and resulting trade allocation concerns are the material
conflicts of interest facing the Fund's advisor. However, we will
add to our existing disclosure in response to the comment to
further elaborate regarding this concern.
COMMENT: TANDY REQUIREMENTS
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As required by the SEC, the Fund acknowledges that:
- The 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.
- 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