EX-99.77B ACCT LTTR

Report of Independent Registered Public
Accounting Firm

To the Board of Trustees of Vanguard Windsor
Funds and the Shareholders of
Vanguard Windsor Fund and
Vanguard Windsor II Fund

In planning and performing our audits of the
financial statements of Vanguard Windsor Fund
and Vanguard Windsor II Fund (constituting
Vanguard Windsor Funds, hereafter referred to
as the ?Trust?) as of and for the year ended
October 31, 2015, in accordance with the
standards of the Public Company Accounting
Oversight Board (United States), we considered
the Trust?s internal control over financial
reporting, including controls over safeguarding
securities, as a basis for designing our auditing
procedures for the purpose of expressing our
opinion on the financial statements and to
comply with the requirements of Form N-SAR,
but not for the purpose of expressing an opinion
on the effectiveness of the Trust?s internal
control over financial reporting.  Accordingly, we
do not express an opinion on the effectiveness of
the Trust?s internal control over financial
reporting.

The management of the Trust is responsible for
establishing and maintaining effective internal
control over financial reporting.  In fulfilling this
responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls.  A
company?s internal control over financial
reporting is a process designed to provide
reasonable assurance regarding the reliability of
financial reporting and the preparation of
financial statements for external purposes in
accordance with generally accepted accounting
principles.  A company's internal control over
financial reporting includes those policies and
procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and
fairly reflect the transactions and dispositions of
the assets of the company; (2) provide reasonable
assurance that transactions are recorded as
necessary to permit preparation of financial
statements in accordance with generally accepted
accounting principles, and that receipts and
expenditures of the company are being made
only in accordance with authorizations of
management and trustees of the company; and
(3) provide reasonable assurance regarding
prevention or timely detection of unauthorized
acquisition, use or disposition of a company?s
assets that could have a material effect on the
financial statements.

Because of its inherent limitations, internal
control over financial reporting may not prevent
or detect misstatements.  Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or
that the degree of compliance with the policies or
procedures may deteriorate.

A deficiency in internal control over financial
reporting exists when the design or operation of
a control does not allow management or
employees, in the normal course of performing
their assigned functions, to prevent or detect
misstatements on a timely basis.  A material
weakness is a deficiency, or a combination of
deficiencies, in internal control over financial
reporting, such that there is a reasonable
possibility that a material misstatement of the
Trust?s annual or interim financial statements
will not be prevented or detected on a timely
basis.

Our consideration of the Trust?s internal control
over financial reporting was for the limited
purpose described in the first paragraph and
would not necessarily disclose all deficiencies in
internal control over financial reporting that
might be material weaknesses under standards
established by the Public Company Accounting
Oversight Board (United States).  However, we
noted no deficiencies in the Trust?s internal
control over financial reporting and its operation,
including controls over safeguarding securities,
that we consider to be material weaknesses as
defined above as of October 31, 2015.

This report is intended solely for the information
and use of management and the Board of
Trustees of Vanguard Windsor Funds and the
Securities and Exchange Commission and is not
intended to be and should not be used by anyone
other than these specified parties.


/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 10, 2015










3

EX-99.77Q1 OTHR EXHB

                           EXHIBIT 77Q3 TO FORM N-SAR

Registrant Name: Vanguard Windsor Fund(s)
File Number: 811-00834
Registrant CIK Number: 0000107606


Items 72, 73 and 74

     Because  the  electronic  format  for filing  Form  N-SAR does not  provide
adequate space for responding to Items 72 through 74 completely,  the Registrant
has set forth in their entirety the complete responses to the indicated Items or
Sub-Items  below,  in  accordance  with  verbal  instructions  provided  to  the
Registrant by the staff of the  Commission on September 20, 2002,  and September
23, 2002.










Series 1 Identifier S000004417
Class 1 SEC Identifier C000012178
Class 2 SEC Identifier C000012179



Item 73

Distributions per share for which record date passed during the period:


B)      1. Distributions of capital gains 					$0.963

        2. Distributions of capital gains from a second class of open-end
company shares  						                          $3.248


Series 2 Identifier S000004418
Class 1 SEC Identifier C000012180
Class 2 SEC Identifier C000012181


Item 73

Distributions per share for which record date passed during the period:


B)      1. Distributions of capital gains 					$2.613

        2. Distributions of capital gains from a second class of open-end
company shares  						                          $4.636