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SEC Company Response from VANGUARD CHESTER FUNDS (CIK 0000752177) — Jun 21, 2022

VANGUARD CHESTER FUNDS (CIK 0000752177)
Date: June 21, 2022 · CIK: 0000752177 · Accession: 0001683863-22-005068

AI Filing Summary & Sentiment

Date
June 21, 2022
Author
/s/ Elizabeth Bestoso
Form
CORRESP
Company
VANGUARD CHESTER FUNDS (CIK 0000752177)

Letter

Washington, DC 20549 File No. 002-92948 Post-Effective Amendment No. 90 – Vanguard Target Retirement 2070 Fund (the “Fund”)

RE: Vanguard Chester Funds

Dear Ms. Larkin,

This letter responds to your comments provided on February 23, 2022, to the above-referenced post-effective amendment.

Comment 1: Principal Investment Strategies

Comment: Consider clarifying that references to “stocks” mean common stocks as opposed to preferred stocks or other instruments.

Response: We have considered the comment and respectfully decline to revise the disclosure. We believe the current disclosure is clear as written, consistent with existing disclosure for other Vanguard Target Retirement Funds, and appropriately conforms to the requirements of Form N-1A.

Comment 2: Principal Investment Strategies

Comment: In the “Principal Investment Strategies” section, there is a sentence that refers to “investment-grade foreign bonds.” Consider clarifying if the other bonds listed are investment-grade.

Response: We have considered the comment and respectfully decline to revise the disclosure. We believe the current disclosure is clear as written, consistent with existing disclosure for other Vanguard Target Retirement Funds, and appropriately conforms to the requirements of Form N-1A.

Please contact me at elizabeth_bestoso@vanguard.com or (610) 669-2531 with any questions or comments regarding the above response.

Sincerely,
/s/ Elizabeth Bestoso

Show Raw Text
CORRESP
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filename1.htm

Vanguard Target Retirement 2070 Fund Correspondence

        June 21, 2022

        Lisa N. Larkin, Esq.

        U.S. Securities and Exchange Commission via electronic filing

        100 F Street, N.E.

        Washington, DC  20549

        RE:             Vanguard Chester Funds

          File No. 002-92948

                           Post-Effective Amendment No. 90 – Vanguard Target Retirement 2070 Fund (the “Fund”)

        Dear Ms. Larkin,

        This letter responds to your comments provided on February 23, 2022, to the above-referenced post-effective amendment.

        Comment 1: Principal Investment Strategies

        Comment: Consider clarifying that references to “stocks” mean common stocks as opposed to preferred stocks or other instruments.

        Response:  We have considered the comment and respectfully decline to revise the disclosure. We believe the current disclosure is clear as written, consistent with existing disclosure for other Vanguard Target Retirement Funds, and appropriately conforms to the requirements of Form N-1A.

        Comment 2:  Principal Investment Strategies

        Comment:  In the “Principal Investment Strategies” section, there is a sentence that refers to “investment-grade foreign bonds.” Consider clarifying if the other bonds listed are investment-grade.

        Response: We have considered the comment and respectfully decline to revise the disclosure. We believe the current disclosure is clear as written, consistent with existing disclosure for other Vanguard Target Retirement Funds, and appropriately conforms to the requirements of Form N-1A.

        Please contact me at elizabeth_bestoso@vanguard.com or (610) 669-2531 with any questions or comments regarding the above response.

        Sincerely,

        /s/ Elizabeth Bestoso

        Elizabeth Bestoso

        Senior Counsel

        The Vanguard Group, Inc.

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