SecProbe.io

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                                     [SHIP]
                               [THE VANGUARD GROUP LOGO]

                                                September 26, 2005

Christian Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission         VIA ELECTRONIC FILING
450 Fifth Street,
N.W., Fifth Floor
Washington, D.C. 20549

Re:        Vanguard Trustees' Equity Fund

Dear Mr. Sandoe:

     The  following  responds to your  comments of September  16,  2005,  on the
post-effective  amendment of the registration  statement of the above-referenced
registrant.  You commented on  Post-Effective  Amendment No.39 that was filed on
August 1, 2005 pursuant to Rule 485(a).

COMMENT 1: PROSPECTUS - PRIMARY INVESTMENT STRATEGIES
-----------------------------------------------------

Comment:  Describe how the Fund  diversifies  its assets  across  developed  and
          emerging markets.

Response: As stated in the Fund's  primary  investment  strategies,  the Fund is
          expected to invest across  developed  and emerging  markets in Europe,
          the Far East,  and  Latin  America.  The  Fund's  shareholder  reports
          describe in more detail the Fund's  holdings for the relevant  period.
          The most recent shareholder report,  dated April 30, 2005, showed that
          the Fund invested 53% of its assets in Europe (across nine countries),
          22% of its assets in the Pacific region (across three countries),  16%
          of its assets in emerging markets (across seven countries),  3% of its
          assets in Canada, and 6% in short-term reserves.

COMMENT 2: PROSPECTUS - AVERAGE ANNUAL TOTAL RETURNS
----------------------------------------------------

Comment:  Explain why the MSCI EAFE Index is the appropriate  comparative  index
          for this Fund.

Response: As of April 30,  2005,  75% of the  Fund's  assets  were  invested  in
          European and Pacific  stocks that are included in the MSCI EAFE Index.
          Based on the  Fund's  holdings  and the  management  of the  Fund,  we
          believe that the MSCI EAFE Index is an appropriate  comparative index.
          We have  decided to add the MSCI All Country  World Index ex USA as an
          additional comparative index in the Fund's prospectus.

<PAGE>

September 26, 2005
Christian Sandoe
Page 2 of 4

COMMENT 3: PROSPECTUS - FREQUENT TRADING OR MARKET-TIMING
---------------------------------------------------------

Comment:  The Fund's  broad  policies  with  respect  to  frequent  trading  and
          market-timing  are  disclosed on page 10 of the  prospectus  under the
          heading  "Frequent  Trading  or  Market-Timing."   However,   specific
          policies  applicable  to discrete  types of investors are disclosed in
          various places throughout the "Investing with Vanguard"  section.  All
          of the Fund's policies  concerning  frequent trading and market-timing
          should be disclosed  together under the heading  "Frequent Trading and
          Market-Timing."

Response: We believe  that the Fund's  policies  against  frequent  trading  and
          market-timing  are properly  disclosed in the  prospectus  pursuant to
          Item 6(e) (4) of Form N-1A.  Item 6(e) (4) does not  require  that the
          specific policies be disclosed together in the prospectus. As such, we
          believe that it is appropriate  to have the general  discussion of the
          Fund's policies against frequent trading and  market-timing  under the
          heading "Frequent  Trading or  Market-Timing"  with a reference to the
          "Investing with Vanguard" section where specific  policies  applicable
          to different types of shareholders and transactions are disclosed.

          We believe  that  removing the  disclosure  from the  "Investing  with
          Vanguard" section and combining the disclosure into a single "Frequent
          Trading  and  Market-Timing"  section  would  make the  discussion  of
          transaction  policies  incomplete  in the  "Investing  with  Vanguard"
          section.  Repeating the specific  policies in both the "Investing with
          Vanguard" section and under the "Frequent  Trading and  Market-Timing"
          heading would  unnecessarily  clutter the prospectus with  duplicative
          disclosure.

COMMENT 4: PROSPECTUS - PLAIN TALK ABOUT THE FUND'S PORTFOLIO MANAGERS
----------------------------------------------------------------------

Comment:  Please describe in more detail the role of each portfolio manager.

Response: We will amend the disclosure to specify that the portfolio managers at
          each of the Fund's investment  advisers co-manage their portion of the
          Fund's  assets.  You have  asked  for more  detail  regarding  how the
          portfolio  managers  co-manage  the  Fund,  but we  believe  that  the
          disclosure as amended is sufficient.

COMMENT 5: PROSPECTUS - FREQUENT-TRADING POLICIES
-------------------------------------------------

Comment:  Please explain why transactions  submitted by mail to Vanguard are not
          subject to the 60-day frequent trading policy.

Response: In our experience,  investors typically do not engage in market-timing
          through  the mail,  and  therefore  the policy does not apply to those
          transactions.  The Fund  reserves  the  right to reject  any  purchase
          request, including purchase requests received by mail.

<PAGE>

September 26, 2005
Christian Sandoe
Page 3 of 4

COMMENT 6: PROSPECTUS - FREQUENT-TRADING POLICIES
-------------------------------------------------

Comment:  Please explain why "certain approved institutional portfolios" are not
          subject to the 60-day frequent trading policy.

Response: Investment  portfolios similar to funds of funds may be established by
          institutional  clients for their employees or clients. Due to the need
          to  periodically  rebalance  these  portfolios,  we will not apply the
          60-day  frequent  trading policy to them. As stated in our response to
          comment 5, the Fund reserves the right to reject any purchase request.

COMMENT 7: STATEMENT OF ADDITIONAL INFORMATION - INVESTMENT LIMITATIONS
-----------------------------------------------------------------------

Comment:  Please   explain  why  the  Fund  does  not  combine  the   investment
          limitations for borrowing and senior securities.

Response: While  the  policies   address  similar  issues,   we  believe  it  is
          appropriate to keep them separate.

COMMENT 8: 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:

          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.

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

                                    * * * * *

          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.

<PAGE>

September 26, 2005
Christian Sandoe
Page 4 of 4

          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)  503-5854  with  any  questions  or  comments
regarding the above responses. Thank you.

Sincerely,

Sarah A. Buescher
Senior Counsel
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