Correspondence 0001683863-25-000449 from VANGUARD INSTITUTIONAL INDEX FUNDS (CIK 0000862084)
VANGUARD INSTITUTIONAL INDEX FUNDS (CIK 0000862084)
Date: Jan. 30, 2025 · CIK: 0000862084 · Accession: 0001683863-25-000449
AI Filing Summary & Sentiment
Letter
Re: Vanguard Institutional Index Funds (the “Trust”) File No. 33-34494 Post-Effective Amendment No. 97
Dear Ms. Larkin,
This letter responds to your comments provided on January 6, 2025, to the above referenced post-effective amendment that was filed with the Commission on November 22, 2024. In this letter, Vanguard Ultra-Short Treasury ETF and Vanguard 0-3 Month Treasury Bill ETF, each a new series of the Trust, will be referred to as the “Fund,” or collectively, the “Funds.”
Vanguard Ultra-Short Treasury ETF
Comment 1:
ETF Summary – Principal Investment Strategies
Comment:
Please consider revising the Fund’s 80% policy to clarify that it includes net assets
plus borrowing.
Response:
The disclosure has been revised in accordance with this comment.
Comment 2:
ETF Summary – Principal Risks
Comment:
Please consider including a concentration risk explaining that the Fund will
concentrate to the extent that the index concentrates.
Response:
The disclosure has been revised in accordance with this comment.
Comment 3:
More on the Fund and ETF Shares – Security Selection
Comment:
In the second paragraph of this section, please consider adding a sentence
disclosing the number of components in the applicable index.
Response:
The disclosure has been revised in accordance with this comment.
Comment 4:
More on the Fund and ETF Shares – Security Selection
P.O. Box 2600
Valley Forge, PA 19482
anthony_coletta@vanguard.com
Comment:
The last sentence of the bullet point that discusses U.S. government
and agency
bonds states, “The Fund may concentrate (invest over 25%) its investments in
government securities.” Please consider changing “may” to “will.”
Response:
The disclosure has been revised in accordance with this comment.
Vanguard 0-3 Month Treasury Bill ETF
Comment 5:
ETF Summary – Principal Investment Strategies
Comment:
Please consider revising the Fund’s 80% policy to clarify that it includes net assets
plus borrowing.
Response:
The disclosure has been revised in accordance with this comment.
Comment 6:
ETF Summary – Principal Risks
Comment:
Please consider including a concentration risk explaining that the Fund will
concentrate to the extent that the index concentrates.
Response:
The disclosure has been revised in accordance with this comment.
Comment 7:
More on the Fund and ETF Shares – Security Selection
Comment:
In the second paragraph of this section, please consider adding a sentence
disclosing the number of components in the applicable index.
Response:
The disclosure has been revised in accordance with this comment.
Comment 8:
More on the Fund and ETF Shares – Security Selection
Comment:
The last sentence of the bullet point that discusses U.S. government and agency
bonds states, “The Fund may concentrate (invest over 25%) its investments in
government securities.” Please consider changing “may” to “will.”
Response:
The disclosure has been revised in accordance with this comment.
Comment 9:
More on the Fund and ETF Shares
Comment:
Vanguard Ultra-Short Treasury ETF has disclosure in this section that states,
“Although falling interest rates tend to strengthen bond prices, they can cause other
problems for bond fund investors—bond calls and prepayments.” Please consider
including this disclosure in the same section for this Fund as well.
Response:
The disclosure has been revised in accordance with this policy.
For Both Funds
Comment 10:
Statement of Additional Information – Fundamental Policies
P.O. Box 2600
Valley Forge, PA 19482
anthony_coletta@vanguard.com
Comment:
In the Industry Concentration policy, please consider clarifying the fundamental
policy by referencing that each Fund will concentrate in government securities to
be consistent with the prospectus.
Response:
The disclosure has been revised in accordance with this comment.
Please contact Sanu Thomas at sanu_thomas@vanguard.com with any questions or comments regarding the above responses.
Sincerely,
/s/ Anthony Coletta
Show Raw Text
CORRESP 1 filename1.htm SEC Comment Response Letter P.O. Box 2600 Valley Forge, PA 19482 anthony_coletta@vanguard.com via electronic filing January 30, 2025 Lisa N. Larkin, Esq. U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Vanguard Institutional Index Funds (the “Trust”) File No. 33-34494 Post-Effective Amendment No. 97 Dear Ms. Larkin, This letter responds to your comments provided on January 6, 2025, to the above referenced post-effective amendment that was filed with the Commission on November 22, 2024. In this letter, Vanguard Ultra-Short Treasury ETF and Vanguard 0-3 Month Treasury Bill ETF, each a new series of the Trust, will be referred to as the “Fund,” or collectively, the “Funds.” Vanguard Ultra-Short Treasury ETF Comment 1: ETF Summary – Principal Investment Strategies Comment: Please consider revising the Fund’s 80% policy to clarify that it includes net assets plus borrowing. Response: The disclosure has been revised in accordance with this comment. Comment 2: ETF Summary – Principal Risks Comment: Please consider including a concentration risk explaining that the Fund will concentrate to the extent that the index concentrates. Response: The disclosure has been revised in accordance with this comment. Comment 3: More on the Fund and ETF Shares – Security Selection Comment: In the second paragraph of this section, please consider adding a sentence disclosing the number of components in the applicable index. Response: The disclosure has been revised in accordance with this comment. Comment 4: More on the Fund and ETF Shares – Security Selection P.O. Box 2600 Valley Forge, PA 19482 anthony_coletta@vanguard.com Comment: The last sentence of the bullet point that discusses U.S. government and agency bonds states, “The Fund may concentrate (invest over 25%) its investments in government securities.” Please consider changing “may” to “will.” Response: The disclosure has been revised in accordance with this comment. Vanguard 0-3 Month Treasury Bill ETF Comment 5: ETF Summary – Principal Investment Strategies Comment: Please consider revising the Fund’s 80% policy to clarify that it includes net assets plus borrowing. Response: The disclosure has been revised in accordance with this comment. Comment 6: ETF Summary – Principal Risks Comment: Please consider including a concentration risk explaining that the Fund will concentrate to the extent that the index concentrates. Response: The disclosure has been revised in accordance with this comment. Comment 7: More on the Fund and ETF Shares – Security Selection Comment: In the second paragraph of this section, please consider adding a sentence disclosing the number of components in the applicable index. Response: The disclosure has been revised in accordance with this comment. Comment 8: More on the Fund and ETF Shares – Security Selection Comment: The last sentence of the bullet point that discusses U.S. government and agency bonds states, “The Fund may concentrate (invest over 25%) its investments in government securities.” Please consider changing “may” to “will.” Response: The disclosure has been revised in accordance with this comment. Comment 9: More on the Fund and ETF Shares Comment: Vanguard Ultra-Short Treasury ETF has disclosure in this section that states, “Although falling interest rates tend to strengthen bond prices, they can cause other problems for bond fund investors—bond calls and prepayments.” Please consider including this disclosure in the same section for this Fund as well. Response: The disclosure has been revised in accordance with this policy. For Both Funds Comment 10: Statement of Additional Information – Fundamental Policies P.O. Box 2600 Valley Forge, PA 19482 anthony_coletta@vanguard.com Comment: In the Industry Concentration policy, please consider clarifying the fundamental policy by referencing that each Fund will concentrate in government securities to be consistent with the prospectus. Response: The disclosure has been revised in accordance with this comment. Please contact Sanu Thomas at sanu_thomas@vanguard.com with any questions or comments regarding the above responses. Sincerely, /s/ Anthony Coletta Anthony Coletta Assistant General Counsel The Vanguard Group, Inc.