Correspondence 0001683863-23-000223 from VANGUARD HORIZON FUNDS (CIK 0000932471)
VANGUARD HORIZON FUNDS (CIK 0000932471)
Date: Jan. 23, 2023 · CIK: 0000932471 · Accession: 0001683863-23-000223
AI Filing Summary & Sentiment
Letter
Washington, DC 20549 Re: Vanguard Horizon Funds (the "Trust") File No. 33-56443 Post-Effective Amendment No. 70 – Vanguard Global Equity Fund
Dear Ms. Larkin:
This letter responds to your comments provided on January 6, 2023, on the above-referenced post" effective amendment. The comments apply to Vanguard Global Equity Fund, a series of the Trust.
Comment 1: On page 9, in the first full paragraph, in factor (3), consider using a plain English description of "positive skew."
Response: We have revised the description and replaced "the range of outcomes has a positive skew" with "Pzena's downside analysis suggests the range of outcomes is more likely than not to be favorable."
Comment 2: On page 9, in the second full paragraph, consider using a plain English description of "secular trends."
Response: We have revised the description and replaced "secular trends" with "consistent patterns over periods of time."
Comment 3: On page 9, in the second full paragraph, "sustainability and ESG" is mentioned the first and only time in the Prospectus. Please describe how ESG is involved with the strategy in this Fund and provide corresponding risk disclosures.
Response: We have revised the disclosure and removed the reference to "sustainability and ESG."
If you have any questions, please contact me at michael_drayo@vanguard.com.
Sincerely,
/s/ Michael Drayo
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Global Equity Fund-SEC Response Letter
P.O. Box 2600
Valley Forge, PA 19482 michael_drayo@vanguard.com
January 23, 2023
Lisa N. Larkin, Esq.
via electronic filing
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Vanguard Horizon Funds (the "Trust")
File No. 33-56443
Post-Effective Amendment No. 70 – Vanguard Global Equity Fund
Dear Ms. Larkin:
This letter responds to your comments provided on January 6, 2023, on the above-referenced post" effective amendment. The comments apply to Vanguard Global Equity Fund, a series of the Trust.
Comment 1: On page 9, in the first full paragraph, in factor (3), consider using a plain English description of "positive skew."
Response: We have revised the description and replaced "the range of outcomes has a positive skew" with "Pzena's downside analysis suggests the range of outcomes is more likely than not to be favorable."
Comment 2: On page 9, in the second full paragraph, consider using a plain English description of "secular trends."
Response: We have revised the description and replaced "secular trends" with "consistent patterns over periods of time."
Comment 3: On page 9, in the second full paragraph, "sustainability and ESG" is mentioned the first and only time in the Prospectus. Please describe how ESG is involved with the strategy in this Fund and provide corresponding risk disclosures.
Response: We have revised the disclosure and removed the reference to "sustainability and ESG."
If you have any questions, please contact me at michael_drayo@vanguard.com.
Sincerely,
/s/ Michael Drayo
Michael Drayo
Associate General Counsel
The Vanguard Group, Inc.