SEC Company Response from VANGUARD WORLD FUND (CIK 0000052848) — Sep 14, 2020
VANGUARD WORLD FUND (CIK 0000052848)
Date: Sept. 14, 2020 · CIK: 0000052848 · Accession: 0001683863-20-013183
AI Filing Summary & Sentiment
Letter
Washington, DC 20549 RE:Vanguard World Fund (the “Trust”) File No. 2-17620 Post-Effective Amendment No. 167
Dear Ms. Larkin,
This letter responds to your comments provided on August 26, 2020, on the above referenced post-effective amendment. The comments apply to Vanguard ESG U.S. Corporate Bond ETF, a series of the Trust (the “Fund”).
Comment 1:
Principal Investment Strategies
Comment:
Please provide more information on what is meant by companies “involved in and/or derive threshold amounts of revenue from certain activities.”
Response:
The disclosure has been revised accordingly.
Comment 2: Principal Investment Strategies
Comment:
Please explain how the index methodology defines “controversial weapons” and “conventional weapons”.
Response:
The disclosure refers shareholders to the “Security Selection” section of the prospectus, which defines these terms.
Comment 3:
Principal Investment Strategies
Comment:
Please provide more information on the index provider’s ESG controversies assessment.
Response:
The disclosure has been revised accordingly.
Comment 4:
Principal Investment Strategies
Comment:
Please clarify how companies that do not report board diversity are assessed under the index methodology.
Response:
The disclosure has been revised accordingly.
Comment 5:
Principal Risks
Comment:
“Interest rate risk” mentions intermediate-term bonds. Please clarify how intermediate bonds will be used in the ETF.
Response:
The disclosure has been revised accordingly.
Comment 6:
Principal Risks
Comment:
To the extent they are considered principal risks, please add “concentration risk” and “tracking risk” to the principal risks section.
Response:
The disclosure has been revised accordingly.
Comment 7:
Security Selection
Comment:
Please state the name of the index provider.
Response:
The disclosure has been revised accordingly.
Comment 8:
Security Selection
Comment:
Please state the approximate number of index constituents in the target index.
Response:
The disclosure has been revised accordingly.
Please contact me at cassandre_juste@vanguard.com with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Cassandre L. Juste
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CORRESP
1
filename1.htm
P.O. Box 2600
Valley Forge, PA 19482-2600
Cassandre_Juste@vanguard.com
September 14, 2020
Lisa N. Larkin, Esq.
U.S. Securities and Exchange Commissionvia electronic filing
100 F Street, N.E.
Washington, DC 20549
RE:Vanguard World Fund (the “Trust”)
File No. 2-17620
Post-Effective Amendment No. 167
Dear Ms. Larkin,
This letter responds to your comments provided on August 26, 2020, on the above referenced post-effective amendment. The comments apply to Vanguard ESG U.S. Corporate Bond ETF, a series of the Trust (the “Fund”).
Comment 1:
Principal Investment Strategies
Comment:
Please provide more information on what is meant by companies “involved in and/or derive threshold amounts of revenue from certain activities.”
Response:
The disclosure has been revised accordingly.
Comment 2: Principal Investment Strategies
Comment:
Please explain how the index methodology defines “controversial weapons” and “conventional weapons”.
Response:
The disclosure refers shareholders to the “Security Selection” section of the prospectus, which defines these terms.
Comment 3:
Principal Investment Strategies
Comment:
Please provide more information on the index provider’s ESG controversies assessment.
Response:
The disclosure has been revised accordingly.
Comment 4:
Principal Investment Strategies
Comment:
Please clarify how companies that do not report board diversity are assessed under the index methodology.
Response:
The disclosure has been revised accordingly.
Comment 5:
Principal Risks
Comment:
“Interest rate risk” mentions intermediate-term bonds. Please clarify how intermediate bonds will be used in the ETF.
Response:
The disclosure has been revised accordingly.
Comment 6:
Principal Risks
Comment:
To the extent they are considered principal risks, please add “concentration risk” and “tracking risk” to the principal risks section.
Response:
The disclosure has been revised accordingly.
Comment 7:
Security Selection
Comment:
Please state the name of the index provider.
Response:
The disclosure has been revised accordingly.
Comment 8:
Security Selection
Comment:
Please state the approximate number of index constituents in the target index.
Response:
The disclosure has been revised accordingly.
Please contact me at cassandre_juste@vanguard.com with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Cassandre L. Juste
Cassandre L. Juste
Associate Counsel
The Vanguard Group, Inc.