[SHIP LOGO VANGUARD(R)]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-503-5693
Natalie_S_Bej@vanguard.com
September 26, 2008
Christian Sandoe, Esq.
U.S. Securities and Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard STAR Funds (the "Trust")
File No. 2-88373
Dear Mr. Sandoe,
This letter responds to your comments of September 22, 2008 on Post-Effective
Amendment No. 46 to the Trust's registration statement that was filed on August
5, 2008.
Comment 1: Prospectus - Fund Profile-Vanguard Developed Markets Index
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Fund (page 1)
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Comment: Why is country risk shown as a primary risk for Developed
Markets Index Fund but country/regional risk is shown as a
primary risk for Total International Stock Index Fund (the
"Fund")?
Response: We will amend the prospectus to disclose country/regional risk
as a primary risk for Developed Markets Index Fund. There
could be situations where that fund's benchmark index invests
a large portion of assets in securities of companies in a
particular region.
Comment 2: Prospectus - More on the Funds (page 10)
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Comment: The disclosure states that Developed Markets Index Fund will
invest at least 80%, and usually all or substantially all, of
its assets in the European and Pacific Stock Index Funds or
other Vanguard funds that use an indexing strategy to invest
in stocks of developed markets. Please explain what is meant
by the phrase "other Vanguard funds."
Response: As disclosed under the primary investment strategies for
Developed Markets Index Fund, the fund currently seeks to
track the performance of the MSCI EAFE Index by investing in
two other Vanguard funds - European Stock Index and Pacific
Stock Index Funds. These two underlying funds seek to track
the MSCI Europe Index and the MSCI Pacific Index, which
together make up the MSCI EAFE Index. If the fund
Christian Sandoe, Esq.
U.S. Securities and Exchange Commission
September 26, 2008
Page 2
were to invest in other underlying funds under the current
investment strategy, the underlying funds together would seek
to track the MSCI EAFE Index. Currently, the fund only invests
in the two identified funds.
Comment 3: Prospectus - Investment Advisor (page 19)
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Comment: Item 5(a)(1)(iii) of Form N-1A requires that the prospectus
include a statement that a discussion regarding the basis for
board approval of an advisory contract is available in the
annual or semi-annual report.
Response: We will amend the prospectus to include the statement.
Comment 4: Statement of Additional Information- Investment Advisory
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Services (page B-39)
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Comment: Please update with disclosure in response to Item 15 of
Form N-1A.
Response: We will provide this disclosure.
Comment 5: 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 610-503-5693 with any questions or comments regarding the
above responses. Thank you.
Sincerely,
Natalie S. Bej
Principal
The Vanguard Group, Inc.