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Vanguard Intermediate-Term Tax-Exempt Bond ETF

        P.O. Box 2600

        Valley Forge, PA 19482

        jeremy_esperon@vanguard.com

        via electronic filing

        January 16, 2024

        Lisa N. Larkin, Esq.

        U.S. Securities and Exchange Commission

        100 F Street, N.E.

        Washington, DC 20549

                    Re:

                    Vanguard Municipal Bond Funds (the "Trust")

                    File No. 2-57689

                    Post-Effective Amendment No. 107 ("PEA No. 107")

        Dear Ms. Larkin,

        This letter responds to your comments provided on December 12, 2023, to PEA No. 107, which was filed with the Commission on October 27, 2023, for the purpose of adding Vanguard Intermediate-Term Tax- Exempt Bond ETF (the "Fund") as a new series of the Trust.

                    Comment 1:

                    Fees and Expenses

                    Comment:

                    Please supplementally confirm that the fee table and expense examples will be

                    completed in the 485(b) filing.

                    Response:

                    Confirmed.

                    Comment 2:

                    Principal Investment Strategies

                    Comment:

                    The last paragraph of this section states that "[u]nder normal circumstances, at least

                    80% of the Fund's assets will be invested in securities whose income will be

                    exempt from federal income taxes and the federal AMT" (emphasis added). Please

                    revise the reference to "securities" to instead state "fixed income securities."

                    Response:

                    The requested change has been made.

                    Comment 3:

                    Security Selection

                    Comment:

                    Please ensure that the Item 9 section includes disclosure regarding the Fund's

                    fundamental 80% investment policy. See instruction 5 to Item 9(b)(1) of Form N-

                    1A.

                    Response:

                    The requested disclosure has been added.

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                    P.O. Box 2600

                    Valley Forge, PA 19482

                    jeremy_esperon@vanguard.com

                    Comment 4:

                    Security Selection

                    Comment:

                    The disclosure states that "the Fund may invest a small portion of its assets in fixed

                    income futures, which are a type of derivative, and/or shares of exchange-traded

                    funds (ETFs)." The Staff notes that the Fund's ability to invest in fixed income

                    futures is also noted earlier in this section. Please consider removing this second

                    reference to fixed income futures.

                    Response:

                    The disclosure has been revised to remove the second reference.

                    Comment 5:

                    Security Selection

                    Comment:

                    Please confirm that the Fund does not invest in instruments traded outside of a

                    collateralized settlement system.

                    Response:

                    Confirmed.

                    Comment 6:

                    Legal Opinion

                    Comment:

                    The Part C states that the Legal Opinion is "Not Applicable." The Staff notes prior

                    correspondence with Vanguard and requests further analysis explaining why this

                    requirement is not applicable.

                    Response:

                    As previously noted to the Staff, a legal opinion was issued in connection with the

                    Trust's initial registration statement filing. Consistent with Delaware law, the

                    representations in that opinion are evergreen and applicable to each series of the

                    Trust, whether currently existing at the time the opinion was issued or subsequently

                    created and thus, a new legal opinion is not required to be filed in connection with

                    the launch of the Fund. Under Delaware law, counsel can issue an opinion at the

                    formation of a trust that all shares of each series and class thereof, when issued

                    against payment therefor as described in and in accordance with the applicable

                    registration statement of the trust and its declaration of trust and bylaws, will be

                    legally issued, fully paid, and nonassessable. This opinion would be "evergreen"

                    in the sense that it would apply to the shares of each series and class existing when

                    the opinion was delivered and the shares of each series and class established after

                    the opinion was delivered.1

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        P.O. Box 2600

        Valley Forge, PA 19482

        jeremy_esperon@vanguard.com

        Please contact me at jeremy_esperon@vanguard.com with any questions or comments regarding the above.

        Sincerely,

        /s/ Jeremy Esperon

        Senior Counsel

        Jeremy Esperon

        The Vanguard Group, Inc.

        1We note that Staff Legal Bulletin 19 focuses on the "registrant" and not the individual series. See Legality and Tax Opinions in Registered Offerings: Staff Legal Bulletin No. 19, Division of Corporation Finance, U.S. Securities and Exchange Commission (October 14, 2011): "The staff understands the phrase "legally issued" (the opinion may say "validly issued") to mean that: (1) the registrant is validly existing under the laws of the jurisdiction in which it is incorporated, and the securities are duly authorized; (2) the actions required by applicable state corporation law to approve the issuance of the securities have been taken; and (3) the securities have been or will be issued in compliance with the requirements of that law, the registrant's certificate or articles of incorporation and bylaws, and the resolutions approving the issuance of those securities. The staff understands the phrase "duly authorized" to mean that the corporation, under applicable law, its certificate or articles of incorporation and its bylaws, has the power to issue the shares and has taken all corporate actions necessary to create that power. The staff understands the phrase "fully paid" to mean that the consideration received by the registrant satisfies, in both type and amount, the requirements of applicable state corporation law, the registrant's certificate or articles of incorporation and bylaws, the resolutions approving the issuance, and any other applicable agreement. Because the opinion must be filed before the registration statement becomes effective, the staff does not object if counsel assumes that the registrant will receive the required consideration." (emphasis added).

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