[VANGUARD SHIP LOGO/R/]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-4294
Michael_Drayo@vanguard.com
May 28, 2009
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 May 20, 2009 on Post-Effective
Amendment No. 49 to the Trust's registration statement that was filed on April
3, 2009.
COMMENT 1: PROSPECTUS - FUND PROFILE-VANGUARD DEVELOPED MARKETS INDEX
FUND
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Comment: Confirm that the term "major markets" in the investment
objective for the fund means developed
markets.
Response: We confirm that the term "major markets" means developed
markets. We will leave this unchanged.
COMMENT 2: PROSPECTUS - PRIMARY INVESTMENT STRATEGIES - VANGUARD TOTAL
INTERNATIONAL STOCK INDEX FUND
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Comment: Is the Fund's index created by Vanguard or an unaffiliated
entity? If the index is created by Vanguard, how is the index
constructed? Consider providing additional disclosure on the
Fund's index.
Response: As disclosed under the primary investment strategies for Total
International Stock Index Fund, the fund tracks the Total
International Composite Index (the "Composite Index"). Since
August 24, 2006, the Composite Index has been the same as the
MSCI EAFE + Emerging Markets Index (the "MSCI Index"). Both
the Composite Index and the MSCI Index are a weighted blend of
the stocks in the MSCI Europe Index, the MSCI Pacific Index,
and the MSCI Emerging Markets Index (collectively, the
"underlying indexes").
The fund tracks the Composite Index (rather than the MSCI
Index) for historical reasons. Prior to August 24, 2006, (i)
the fund obtained its emerging markets exposure through a
mutual fund that tracked the Select Emerging Markets Index
(rather than the MSCI Emerging Markets Index), and (ii) the
Composite Index was a weighted blend of the stocks in the MSCI
Europe Index, the MSCI Pacific Index, and the Select Emerging
Markets Index (rather than the MSCI Emerging Markets Index).
The Select Emerging Markets Index was a customized version of
the MSCI Emerging Markets Index administered exclusively for
Vanguard by MSCI.
On August 24, 2006, the fund began to obtain its emerging
markets exposure through a mutual fund that tracks the MSCI
Emerging Markets Index (rather than the Select Emerging
Markets Index). Since that date, the performance of the
Composite Index and the MSCI Index has been the same. Since
March 12, 2009, the Fund has obtained exposure to the
Composite Index by investing directly in securities included
in the Composite Index, rather than indirectly through
Vanguard mutual funds.
The performance of the Composite Index is calculated by
Vanguard based upon the market-value-weighted returns of the
underlying indexes, which are calculated by MSCI. We will
provide additional disclosure on the fund's index in the
prospectus and SAI.
COMMENT 3: PROSPECTUS - INVESTMENT ADVISOR
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Comment: Portfolio managers need to be listed for the Developed Markets
Index Fund.
Response: We will amend the prospectus to include this information.
COMMENT 4: PROSPECTUS - PRIMARY RISKS - VANGUARD DEVELOPED MARKETS INDEX
FUND AND VANGUARD TOTAL INTERNATIONAL STOCK INDEX FUND
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Comment: Consider including additional risk disclosure of investing in
a specific country if a fund commits a substantial amount of
its assets to issuers located in the country.
Response: We will add additional risk disclosure to highlight that each
fund is particularly exposed to the risks associated with
investing in issuers located in Japan and the United Kingdom.
COMMENT 5: TANDY REQUIREMENTS
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As required by the SEC, the Fund acknowledges that:
o The Funds are 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 Securities and Exchange Commission
from taking any action with respect to the filing.
o The Funds may not assert staff comments as a defense in any proceeding
initiated by the Securities and Exchange Commission or any person under the
federal securities laws of the United States.
Please contact me at 610-669-4294 with any questions or comments regarding the
above responses. Thank you.
Sincerely,
Michael Drayo
Associate Counsel
The Vanguard Group, Inc.