[SHIP LOGO VANGUARD/(R)/]
P.O. Box 2600
Valley Forge,PA
19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
October 17, 2007
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: VANGUARD BOND INDEX FUNDS
Dear Mr. Sandoe,
The following summarizes our discussion of this afternoon regarding
comments to Post-effective Amendment No. 46 of Vanguard Bond Index Funds'
registration statement. The Post-Effective Amendment was filed on August 30,
2007. The comments pertain to Vanguard Inflation-Protected Securities Fund.
COMMENT 1: PROSPECTUS - PRIMARY RISKS
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COMMENT: Since the Fund's Primary Investment Strategies reference
investment in corporations, credit risk should be included in Primary
Risks.
RESPONSE: The Fund invests in inflation-indexed bonds issued "by the U.S.
government, its agencies and instrumentalities, and corporations," meaning
corporations of the U.S. government, rather than "business" corporations.
Examples of the government corporations in which the Fund invests are FNMA
and GNMA. Per the Fund's most recent semiannual report, 99.8% of the Fund's
assets were invested in U.S. Treasury Inflation-Indexed notes, and the Fund
had an average credit quality of Aaa. For all of these reasons, we are
satisfied that we currently disclose the relevant primary risks, and we
plan to leave the current disclosure unchanged.
COMMENT 2: PROSPECTUS - FINANCIAL INFORMATION
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COMMENT: Will Vanguard's 485(b) filing include updated financials?
RESPONSE: Yes, our 485(b) filing will include updated financials.
COMMENT 3: PROSPECTUS - PLAIN TALK ABOUT THE FUND'S PORTFOLIO MANAGERS
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COMMENT: If the Fund has more than one Portfolio Manager, please specify
the role played by each in managing the Fund's assets.
RESPONSE: We have discussed the comment with the Portfolio Managers of the
Fund, and they have confirmed that the existing disclosure whereby the PMs
are referred to as "co-managers" is an accurate description of their roles.
The PMs work together in managing fund assets, sharing in the determination
of strategies and risk exposures, and placing trades on behalf of the Fund.
Furthermore, we believe that our existing disclosure satisfies the
requirements of Item 5(a)(2) of Form N-1A. Accordingly, we do not plan to
amend the disclosure.
COMMENT 4: SAI - PORTFOLIO TRANSACTIONS
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COMMENT: Please edit the first sentence in the second full paragraph on
Page B-39 to clarify which funds did not pay any brokerage commissions
during their past three fiscal years.
RESPONSE: We will edit the sentence as requested.
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) 669-1538 with any questions or comments
regarding the above responses. Thank you.
Sincerely,
Judith L. Gaines
Associate Counsel
Securities Regulation, Legal Department