CORRESP 1 filename1.htm seccommentletterfixedincomes.htm - Generated by SEC Publisher for SEC Filing

    P.O. Box 2600
    Valley Forge, PA 19482-2600
    610-669-1955
    tara_r_buckley@vanguard.com
 
January 30, 2012  
 
Brion Thompson, Esq.  
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.  
Washington, DC 20549  
 
RE: Vanguard Fixed Income Securities Funds; File No. 2-47371

 

Dear Mr. Thompson:

The following responds to your comments of December 20, 2011 on the post-effective amendment of the above-referenced registrant. You commented on Post-Effective Amendment No. 91, which was filed on November 22, 2011 pursuant to Rule 485(a).

Comment 1: Short-Term Treasury Fund – Prospectus – Primary Investment
  Strategies
 
Comment: The Primary Investment Strategies section states that the dollar-weighted
  average maturity for the Fund will be 1-4 years. The staff takes the
  position that the average maturity for a short-term fund is 1-3 years.
 
Response: The adopting release for rule 35d-1 states that the purpose of the rule is to
  prevent investment companies from adopting names that could mislead
  investors about a fund’s investments and risks. In the adopting release, the
  SEC provided guidance that the dollar-weighted average maturity for a
  short-term bond fund should not exceed 3 years. The text of the rule,
  however, does not require a 3-year maturity for short-term funds. We
  believe that under any reasonable interpretation of the adopting release
  and rule 35d-1, a dollar-weighted average maturity range of 1- 4 years
  qualifies as “short-term.” For these reasons, we believe that the names of
  the Vanguard Short-Term Treasury, Short-Term Federal and Short-Term
  Investment Grade Funds are not misleading.
 
Comment 2: Long-Term Investment-Grade Fund – Prospectus – Primary
  Investment Strategies
 
Comment: Add disclosure to the Primary Investment Strategies section identifying
  the dollar-weighted average maturity of the fund’s benchmark index.
 
Response: We have added the requested disclosure.

 

0234567


 

Brion Thompson, Esq.
January 30, 2012
Page 2

Tandy Requirements

As required by the SEC, each 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) 669-1955 with any questions or comments regarding the above responses and explanations.

Sincerely,

Tara R. Buckley
Senior Counsel
The Vanguard Group, Inc.