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[SHIP LOGO VANGUARD /(R)/]
P.O.Box 2600
Valley Forge, PA 19482-2600
610-669-2627
Laura_J_Merianos@vanguard.com
May 18, 2007
Christian Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission via electronic filing
450 Fifth Street,N.W., Fifth Floor
Washington, D.C. 20549
RE: VANGUARD FIXED INCOME SECURITIES FUNDS
Dear Mr. Sandoe:
The following responds to your comments of May 15, 2007 on the
post-effective amendment of the registration statement of the above-referenced
registrant. You commented on Post-Effective Amendment No. 82 that was filed on
March 26, 2007.
COMMENT 1: PROSPECTUS - AN INTRODUCTION TO VANGUARD BOND FUNDS
Comment: The chart under the heading "An Introduction to Vanguard Bond
Funds" states that the dollar-weighted average maturity for
each of the Short-Term Treasury, Short-Term Federal and Short-
Term Investment Grade Funds will be 1- 4 years. The adopting
release for rule 35d-1 states that the dollar-weighted average
maturity for short-term bond funds should be no more than
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: PROSPECTUS - PLAIN TALK ABOUT THE FUNDS' PORTFOLIO MANAGERS
Comment: The prospectus indicates that both Thomas Pappas and Michael
Garrett comanage the GNMA Fund. Please confirm that the term
"comanage" means that the portfolio managers are coequals with
respect to their management duties for the Fund.
Response: Mr. Pappas and Mr. Garrett are coequals with respect to their
management duties for the GNMA Fund. We intend for
the term "comanage" to be synonymous with the term "coequal."
COMMENT 3: PROSPECTUS: FEES AND EXPENSES, FOOTNOTE 2 AND LOW-BALANCE ACCOUNTS
POLICY
Comment: Footnote 2 under the Fees and Expenses chart states that
Vanguard will apply a redemption fee to shares redeemed within
one year of purchase by selling or by exchanging to another
fund, or when Vanguard applies its low-balance account-closure
policy. Please clarify in this footnote that the redemption
fee may apply even if the low-balance account-closure policy
is enforced due to a declining NAV. Also, please revise the
low-balance accounts policy to clarify that the policy applies
even when market fluctuations cause a shareholder's account
balance to decline below the investment minimum.
Response: We have revised footnote 2 under the Fees and Expenses table
to clarify that a redemption fee may apply when shares are
redeemed because a fund account balance has fallen below the
investment minimum for any reason, including market
fluctuations.
We have revised our low-balance accounts policy to clarify
that the policy applies even when market fluctuations cause a
shareholder's fund account balance to fall below the
investment minimum.
COMMENT 4: PROSPECTUS: PROPOSED DISCLOSURE FOR INVESTING IN ETF SHARES
Comment: During our telephone call on May 15, 2007, you indicated that
Vanguard would add additional disclosure language to the
prospectus through a 485(b) filing to permit certain bond
funds to invest a small portion of their assets in ETF shares
under certain circumstances. Please include the proposed
disclosure language in your response.
Response: As we discussed, we propose to permit certain Vanguard bond
funds to invest a small portion of their assets in ETF shares.
The purchase of ETF shares will occur on the open market, and
no fund will purchase its own ETF shares. At this time, we do
not expect the expense of investing in ETFs to equal or exceed
1 basis point. We have determined, therefore, that no
additional fee table disclosure is necessary at this time. The
proposed language is as follows:
"Vanguard may invest a small portion of the Short-Term,
Intermediate-Term and Long-Term Investment Grade Funds' assets
in shares of bond exchange-traded funds (ETFs). ETFs provide
returns similar to those of the bonds listed in the index or a
subset of the index. Vanguard may purchase ETFs when doing so
will facilitate cash management or potentially add value
because the instruments are favorably priced. Vanguard
receives no additional revenue from investing Fund assets in
Vanguard bond ETFs because Fund assets invested in ETF Shares
are excluded when allocating to the Fund its share of the
costs of Vanguard operations."
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) 669-2627 with any questions or comments
regarding the above responses. Thank you.
Sincerely,
Laura J Merianos
Associate Counsel
Securities Regulation, Legal Department