[Vanguard Ship Logo]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
August 13, 2007
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing 100 F Street, N.E.
Washington, DC 20549
RE: Vanguard World Funds
Dear Mr. Sandoe,
The following follows our discussion of August 9, 2007 regarding your
comments on the post-effective amendment of the registration statement of the
above-referenced registrant. You commented on Post-Effective Amendment No. 103
that was filed on June 25, 2007. All comments pertain to Vanguard Extended
Duration Treasury Index Fund.
Comment 1: Prospectus - Primary Investment Strategies
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Comment: The fund has a stated policy of investing at least 80% of its
assets in the securities held by its target index. This
disclosure is consistent with Investment Company Act Rule
35d-1; accordingly, no modification is required. However,
normally an index fund would be invested above 80% in the
securities held in the index. Is this the case with the fund?
Response: Yes. The fund will typically invest well over 80% of its
assets in the securities of the index it tracks. However, we
prefer to keep the existing disclosure as it is consistent
with that of our existing bond index funds.
Comment 2: Prospectus - Primary Investment Strategies
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Comment: The word "duration" appears in the fund name, but the duration
is not disclosed in the prospectus. Consider identifying the
fund's duration, and explain why the target index is an
extended duration index.
Response: We will incorporate the fund's duration into the primary
investment strategies in response to the comment. We also plan
to add a definition of "duration" to the glossary at the back
of the prospectus. We consider the target index to be an
extended duration index because since we are investing in zero
coupon bonds, the average maturity and duration will be
approximately the same, and we consider 20-30 years to
constitute extended duration.
Comment 3: Prospectus - Market Exposure
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Comment: Consider whether original issue discount ("OID") constitutes a
primary risk of the fund and, if so, include disclosure in
response to Item 2.
Response: We do not consider OID to constitute a primary risk. The risks
that would result in the event that OID caused the fund to
sell securities are similar to the risks posed when any fund
is required to sell securities to meet redemptions or for
other reasons, and are already disclosed in the fund's Item 2
disclosure.
Comment 4: Prospectus - Fee Table
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Comment: Are the costs of acquiring ETF shares required to be disclosed
in the fund's fee table?
Response: No. In the SEC's fund of funds release, the Commission permits
funds to omit the new separate line item if the aggregate
expenses attributable to acquired funds do not exceed 0.01% of
average net assets of the acquiring fund. This is the case
with respect to the fund's investment in ETFs and/or CMT
funds. Accordingly, the separate line item is omitted from the
Item 2 fee table for the fund.
Comment 5: Prospectus - Frequent Trading or Market Timing
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Comment: The fund's broad policies with respect to frequent trading and
market-timing are disclosed under the heading "Frequent
Trading or Market-Timing." However, specific policies
applicable to discrete types of investors are disclosed in
various places throughout the "Investing with Vanguard"
section. All of the fund's policies concerning frequent
trading and market-timing should be disclosed together under
the heading "Frequent Trading and Market-Timing."
Response: We believe that the fund's policies against frequent trading
and market-timing are properly disclosed in the prospectus
pursuant to Item 6(e)(4) of Form N-1A. Item 6(e)(4) does not
require that the specific policies applicable to each type of
shareholder be disclosed together in the prospectus. As such,
we believe that it is appropriate to have the general
discussion of the fund's policies against frequent trading and
market-timing under the heading "Frequent Trading or
Market-Timing" with a reference to the "Investing with
Vanguard" section where specific policies applicable to
different types of shareholders and transactions are
disclosed.
We believe that removing the disclosure from the "Investing
with Vanguard" section and combining the disclosure into a
single "Frequent Trading and Market-Timing" section would make
the discussion of transaction policies incomplete in the
"Investing with Vanguard" section. Repeating the specific
policies in both the "Investing with Vanguard" section and
under the "Frequent Trading and Market-Timing" heading would
unnecessarily clutter the prospectus with duplicative
disclosure.
Comment 6: Prospectus - Frequent Trading or Market Timing
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Comment: The prospectus indicates that short-term bond funds
accommodate frequent trading. Please confirm if this
disclosure is appropriate.
Response: The frequent trading policy does not apply to short-term bond
funds. The number of exchanges into and out of a short-term
bond fund is not limited. Accordingly, we do not plan to amend
the disclosure.
Comment 7: Prospectus - Plain Talk about the Fund's Portfolio Managers
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Comment: Please clarify the role played by the various portfolio managers.
Response: We have confirmed that the existing disclosure whereby
portfolio managers are referred to as "co-managers" is an
accurate description of their roles. The portfolio managers
are truly equals and work together in managing Fund assets,
sharing in the determination of strategies and risk exposures,
and placing trades on behalf of the respective advisory firms'
portions of the Fund's assets. Neither PM reports to or
presides over the other, nor are there limitations placed on
the roles or responsibilities of the portfolio managers. In
all cases, the advisory firms have represented that the
current PM disclosure accurately describes the roles played by
the portfolio managers in their management of fund assets.
Furthermore, we believe that our existing disclosure satisfies
the requirements of Item 5(a)(2) of Form N-1A. Accordingly, we
do not plan to amend the disclosure.
Comment 8: Prospectus - Plain Talk about the Fund's Portfolio Managers
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Comment: Please clarify that Kenneth Volpert has managed funds for
Vanguard for 5 years or more.
Response: We will clarify in Mr. Volpert's bio that he has managed funds
at Vanguard since 1992
Comment 9: Prospectus - Back Cover
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Comment: Clarify that the shareholder reports and the SAI are available
at no charge at Vanguard's website.
Response: We will add the requested clarification. We'll make
corresponding changes for all of our other fund prospectuses
as well.
Comment 10: Prospectus and SAI
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Comment: Include updated financial information with the 485(b) filing
that responds to SEC comments.
Response: We will include the updated financial information as planned,
and in response to the comment.
Comment 11: 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