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SEC Company Response from VANGUARD FIXED INCOME SECURITIES FUNDS (CIK 0000106444) — May 19, 2005

VANGUARD FIXED INCOME SECURITIES FUNDS (CIK 0000106444)
Date: May 19, 2005 · CIK: 0000106444 · Accession: 0000932471-05-000828

AI Filing Summary & Sentiment

Date
May 19, 2005
Author
Frances T. Han
Form
CORRESP
Company
VANGUARD FIXED INCOME SECURITIES FUNDS (CIK 0000106444)

Letter

{SHIP GRAPHIC} VANGUARD (R) May 19, 2005 Christian Sandoe, Esq. Division of Investment Management U.S. Securities and Exchange Commission via e-mail 450 Fifth Street, N.W., Fifth Floor Washington, D.C. 20549

Re: VANGUARD FIXED INCOME SECURITIES FUNDS: FILE NO. 2-47371

Dear Mr. Sandoe:

Thank you for your comments of May 13, 2005 on the post-effective amendment of the registration statement of Vanguard Fixed Income Securities Funds. You commented on post-effective amendment number 75 that was filed on March 30, 2005 pursuant to Rule 485(a). The following are our responses to each of your comments.

Comment 1: Bond Funds (prospectus page 1)

Comment: Move the "Bonds and Interest Rates" section of "An Introduction to Vanguard Bond Funds" to the "More on the Funds" section of the prospectus.

Response: We have moved the "Bonds and Interest Rates" section of the introduction on page 1 of the prospectus to the "More on the Funds" section of the prospectus. We have replaced the paragraph immediately following the income risk flag on page 29 with the language attached hereto as Exhibit A.

Comment 2: High-Yield Corporate Fund (prospectus page 1)

Comment: The "Primary Investment Strategies" section states that "High-yield bonds mostly have short- and intermediate-term maturities." Include the Fund's expected average maturity in this section.

Response: The Fund's advisor manages the Fund with a focus on credit quality as described in the "Primary Investment Strategies" section, not toward a specific maturity target. The average maturity of the Fund is merely a function of the maturities of the bonds that have been selected by the advisor at any given time and may vary depending on the market supply of high-yield corporate bonds that are available for acquisition by the Fund. Accordingly, it would be misleading to provide the Fund's expected average maturity as a primary investment strategy of the Fund when the advisor does not consider the maturities of the underlying bonds in making its investment decisions.

<PAGE>

Christian Sandoe, Esq. U.S. Securities and Exchange Commission May 19, 2005 Page 2

Comment 3: Inflation-Protected Securities Fund (prospectus page 10)

Comment: In the "Investment Advisor" section of the prospectus, better clarify that George Sauter and Robert Auwaerter oversee, rather than provide the day-to-day management for, the Inflation-Protected Securities Fund.

Response: We believe that the disclosure is clear as written. The paragraph describing Mr. Sauter states that he is responsible for the "oversight of approximately $588 billion managed by Vanguard's Quantitative Equity and Fixed Income Groups." The paragraph describing Mr. Auwaerter states that he has "direct oversight responsibility for all money market, bond, and stable value portfolios, which are managed by the Fixed Income Group..." Furthermore, the introduction to the "Plain Talk About The Fund's Portfolio Managers" clearly states that the individuals listed in the highlighted "Plain Talk" box are "primarily responsible for the day-to-day management of the Fund's portfolios." In light of our clear statements about the roles of each individual, we do not believe that it is necessary to state that Messrs. Sauter and Auwaerter do not have day-to-day management responsibilities for the Inflation-Protected Fund.

Comment 4: Inflation-Protected Securities Fund (prospectus page 10)

Comment: In the "Plain Talk About The Fund's Portfolio Managers" section, identify how long each portfolio manager has managed the Fund and clarify each manager's role in the management of the Fund.

Response: The portfolio managers have jointly managed the Fund since its inception, with equal management responsibility. We will add the following sentence to Mr. Hollyer's disclosure immediately before his education disclosure: "Mr. Hollyer has co-managed the Fund since its inception." We will add the following sentence to Mr. Volpert's disclosure immediately before his education disclosure: "Mr. Volpert has co-managed the Fund since its inception."

Comment 5: Tandy requirements

Comment: The SEC is now requiring all registrants to provide at the end of response letters to registration statement comments, the following statements: - Each 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. - Each 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.

Response: As required by the SEC, we will provide the foregoing acknowledgements.

<PAGE> Christian Sandoe, Esq. U.S. Securities and Exchange Commission May 19, 2005 Page 3

* * * * *

As required by the SEC, the Funds acknowledge that:

- The Funds are 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 Funds 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 call me at (610) 503-5804 if you have any further questions.

Sincerely,
Frances T. Han
Associate Counsel
The Vanguard Group, Inc.

Show Raw Text
<DOCUMENT>
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<TEXT>

                           {SHIP GRAPHIC} VANGUARD (R)

                                 May 19, 2005

Christian Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission                               via e-mail
450 Fifth Street, N.W., Fifth Floor
Washington, D.C. 20549

          Re:   VANGUARD FIXED INCOME SECURITIES FUNDS: FILE NO. 2-47371

Dear Mr. Sandoe:

     Thank you for your comments of May 13, 2005 on the post-effective amendment
of the  registration  statement of Vanguard Fixed Income  Securities  Funds. You
commented on post-effective amendment number 75 that was filed on March 30, 2005
pursuant  to  Rule  485(a).  The  following  are our  responses  to each of your
comments.

Comment 1:  Bond Funds (prospectus page 1)

Comment:    Move the "Bonds and Interest Rates" section of "An Introduction to
            Vanguard Bond Funds" to the "More on the Funds" section of the
            prospectus.

Response:   We have moved the "Bonds and Interest Rates" section of the
            introduction on page 1 of the prospectus to the "More on the
            Funds" section of the prospectus. We have replaced the
            paragraph immediately following the income risk flag on page
            29 with the language attached hereto as Exhibit A.

Comment 2:  High-Yield Corporate Fund (prospectus page 1)

Comment:    The "Primary Investment Strategies" section states that "High-yield
            bonds mostly have short- and intermediate-term maturities."  Include
            the Fund's expected average maturity in this section.

Response:   The Fund's advisor manages the Fund with a focus on credit quality
            as described in the "Primary Investment Strategies" section, not
            toward a specific maturity target.  The average maturity of the Fund
            is merely a function of the maturities of the bonds that have been
            selected by the advisor at any given time and may vary depending on
            the market supply of high-yield corporate bonds that are available
            for acquisition by the Fund.  Accordingly, it would be misleading to
            provide the Fund's expected average maturity as a primary investment
            strategy of the Fund when the advisor does not consider the
            maturities of the underlying bonds in making its investment
            decisions.

<PAGE>

Christian Sandoe, Esq.
U.S. Securities and Exchange Commission
May 19, 2005
Page 2

Comment 3:  Inflation-Protected Securities Fund (prospectus page 10)

Comment:    In the "Investment Advisor" section of the prospectus, better
            clarify that George Sauter and Robert Auwaerter oversee,
            rather than provide the day-to-day management for, the
            Inflation-Protected Securities Fund.

Response:   We believe that the disclosure is clear as written.  The paragraph
            describing Mr. Sauter states that he is responsible for the
            "oversight of approximately $588 billion managed by Vanguard's
            Quantitative Equity and Fixed Income Groups."  The paragraph
            describing Mr. Auwaerter states that he has "direct oversight
            responsibility for all money market, bond, and stable value
            portfolios, which are managed by the Fixed Income Group..."
            Furthermore, the introduction to the "Plain Talk About The Fund's
            Portfolio Managers" clearly states that the individuals listed in
            the highlighted "Plain Talk" box are "primarily responsible for the
            day-to-day management of the Fund's portfolios." In light of our
            clear statements about the roles of each individual, we do not
            believe that it is necessary to state that Messrs. Sauter and
            Auwaerter do not have day-to-day management responsibilities for the
            Inflation-Protected Fund.

Comment 4:  Inflation-Protected Securities Fund (prospectus page 10)

Comment:    In the "Plain Talk About The Fund's Portfolio Managers"
            section, identify how long each portfolio manager has managed
            the Fund and clarify each manager's role in the management of
            the Fund.

Response:   The portfolio managers have jointly managed the Fund since its
            inception, with equal management responsibility. We will add
            the following sentence to Mr. Hollyer's disclosure immediately
            before his education disclosure: "Mr. Hollyer has co-managed
            the Fund since its inception." We will add the following
            sentence to Mr. Volpert's disclosure immediately before his
            education disclosure: "Mr. Volpert has co-managed the Fund
            since its inception."

Comment 5:  Tandy requirements

Comment:    The SEC is now requiring all registrants to provide at the end of
            response letters to registration statement comments, the following
            statements:
            -  Each 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.
            -  Each 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.

Response:   As required by the SEC, we will provide the foregoing
            acknowledgements.

<PAGE>
Christian Sandoe, Esq.
U.S. Securities and Exchange Commission
May 19, 2005
Page 3

                                * * * * *

As required by the SEC, the Funds acknowledge that:

- The Funds are 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 Funds 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 call me at (610) 503-5804 if you have any further questions.

                                        Sincerely,

                                        Frances T. Han
                                        Associate Counsel
                                        The Vanguard Group, Inc.

<PAGE>
                                   EXHIBIT A

================================================================================
                                PLAIN TALK ABOUT
                            BONDS AND INTEREST RATES

As a rule,  when  interest  rates rise,  bond prices fall.  The opposite is also
true:  Bond  prices go up when  interest  rates  fall.  Why do bond  prices  and
interest  rates move in opposite  directions?  Let's assume that you hold a bond
offering a 5% yield.  A year later,  interest rates are on the rise and bonds of
comparable   quality  and   maturity   are  offered   with  a  6%  yield.   With
higher-yielding bonds available, you would have trouble selling your 5% bond for
the price you paid--you  would probably have to lower your asking price.  On the
other hand, if interest rates were falling and 4% bonds were being offered,  you
should be able to sell your 5% bond for more than you paid.

How  mortgage-backed  securities are different:  In general,  declining interest
rates will not lift the prices of mortgage-backed  securities--such as GNMAs--as
much as the prices of comparable  bonds.  Why? Because when interest rates fall,
the bond market tends to discount the prices of  mortgage-backed  securities for
prepayment risk--the  possibility that homeowners will refinance their mortgages
at lower rates and cause the bonds to be paid off prior to maturity.  In part to
compensate for this prepayment possibility,  mortgage-backed  securities tend to
offer higher yields than other bonds of comparable credit quality and maturity.

================================================================================

     Although  bonds are often thought to be less risky than stocks,  there have
been  periods  when bond  prices  have  fallen  significantly  because of rising
interest  rates.  For  instance,  prices of  long-term  bonds fell by almost 48%
between December 1976 and September 1981.

     To illustrate the relationship  between bond prices and interest rates, the
following  table shows the effect of a 1% and a 2% change  (both up and down) in
interest rates on the values of three noncallable bonds of different maturities,
each with a face value of $1,000.

  ---------------------------------------------------------------------------
                        HOW INTEREST RATE CHANGES AFFECT
                          THE VALUE OF A $1,000 BOND*
-----------------------------------------------------------------------------
                            AFTER A 1%   AFTER A 1%   AFTER A 2%   AFTER A 2%
TYPE OF BOND (MATURITY)       INCREASE     DECREASE     INCREASE     DECREASE
-----------------------------------------------------------------------------
Short-Term (2.5 Years)            $977       $1,024         $954       $1,049
Intermediate-Term (10 Years)       922        1,086          851        1,180
Long-Term (20 Years)               874        1,150          769        1,328
-----------------------------------------------------------------------------
*Assuming a 4% coupon.
-----------------------------------------------------------------------------

     These figures are for  illustration  only; you should not regard them as an
indication  of future  returns  from the bond  market as a whole or the Funds in
particular.
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