P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2531
Elizabeth_Bestoso@vanguard.com
February 26, 2020
Lisa N. Larkin, Esq.
U.S. Securities and Exchange Commissionvia electronic filing
100 F Street, N.E.
Washington, DC 20549
RE:Vanguard Windsor Funds (the “Trust”)
File No. 002-14336
Post-Effective Amendment No. 137 – Vanguard Windsor II Fund (the “Fund”)
Dear Ms. Larkin,
This letter responds to your comments provided on January 31, 2020, to the above referenced post-effective amendment.
Comment 1: | Fund Summary |
Comment: | In the “Annual Fund Operating Expenses” section, please confirm that the change to the advisory fee is consistent with the applicable agreement(s) and the terms of the exemptive relief. |
Response: | We confirm that the change to advisory fee is consistent with the applicable agreement(s) and the terms of the exemptive relief. |
Comment 2: | Investment Advisors |
Comment: | In the “Investment Advisors” section, please add any disclosure required by Item 10(a) Instructions 1, 2, and/or 3 of Form N1-A if applicable. |
Response: | We have added the start date for the new advisor, Aristotle Capital Management LLC, pursuant to Instruction 1. |
Comment 3: | Financial Highlights |
Comment: | If the information included in the Financial Highlights is more than 245 days old, unaudited six-month financials must be included with the 485(a) filing. |
Response: | The 485(b) filing will include updated Financial Highlights figures. |
Please contact me at (610) 669-2531 with any questions or comments regarding the above response. Thank you.
Sincerely,
/s/ Elizabeth Bestoso
Elizabeth Bestoso
Associate Counsel
The Vanguard Group, Inc.