P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2689
nathan_m_will@vanguard.com
May 31, 2011
Brion Thompson, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Trustees’ Equity Fund
Dear Mr. Thompson:
The following responds to your comments of May 16 and 18, 2011 on the post-effective amendment of the above-referenced registrant (the “Trust”) and its series, Vanguard Emerging Markets Select Stock Fund (the “Fund”). You commented on Post-Effective Amendment Nos. 56 and 57, which were filed on March 28, 2011, and April 15, 2011 pursuant to Rule 485(a).
Comment 1: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund invests mainly in “equity securities of companies located in emerging markets.” Please add disclosure explaining how the Fund determines whether a company is “located in” an emerging market.
Response: We will add the requested disclosure.
Comment 2: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund invests mainly in “equity securities of companies located in emerging markets.” Please add disclosure explaining how the Fund determines whether a particular market is an “emerging market.”
Response: We will add the requested disclosure.
Comment 3: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund will invest at least 80% of its assets in “stocks” of companies located in emerging markets. Please specify the type of stock in which the Fund will invest.
Response: We will add the requested disclosure.
Comment 4: Statement of Additional Information – Officers and Trustees
Comment: Please include disclosure indicating that the Fund’s Chairman of the Board is an “interested person” as defined in the 1940 Act.
Response: We will add the requested disclosure.
Tandy Requirements
As required by the SEC, the 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) 669-2689 with any questions or comments regarding the above responses and explanations.
Sincerely,
Nathan Will
Associate Counsel
The Vanguard Group, Inc.