SHIP LOGO VANGUARD(R)
P.O. Box 2600 Valley Forge,
PA 19482-2600
610-503-2398
Barry_A_Mendelson@vanguard.com
April 22, 2008
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: VANGUARD EXPLORER FUND
FILE NO. 2-27203
Dear Mr. Sandoe,
The following responds to your comments of April 14, 2008 on the
post-effective amendment of the registration statement of the above-referenced
registrant. You commented on Post-Effective Amendment No. 81 that was filed on
February 26, 2008.
COMMENT: On page 37 of the prospectus, under the heading "Low Balance
Accounts," you state that the fund reserves the right to liquidate any account
whose balance falls below the minimum initial investment amount. Please clarify
that this is not the case for Admiral shareholders.
RESPONSE: The sentence will be rewritten to add clarifying language, as
follows (new language is capitalized): "The Fund reserves the right, without
prior notice, to liquidate any investment-only retirement-plan fund account or
any nonretirement fund account whose balance falls below the INVESTOR SHARES
minimum initial investment for any reason, including market fluctuation." We
will make conforming changes to prospectuses of other Vanguard funds over the
summer.
* * * * * * * *
COMMENT: TANDY REQUIREMENTS
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As required by the SEC, the Funds acknowledge 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.
Sincerely,
Barry A. Mendelson
Principal
The Vanguard Group, Inc.
Enclosures
cc: Christian Sandoe, Esq.
U.S. Securities and Exchange Commission