Vanguard Windsor Funds
                                 P.O. Box 2600
                             Valley Forge, PA 19482
                                 (610) 669-1000

                               February 26, 2007

United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention:  Ruth Sanders, Senior Counsel

         Re:      Vanguard Windsor Funds (the "Trust")
                  Registration No. 2-14336
                  File No. 811-834

Dear Ms. Sanders:

     Pursuant  to Rule  477(a)  under  the  Securities  Act of 1933,  the  Trust
requests the  withdrawal of  Post-Effective  Amendment No. 108, filed January 8,
2007   (the   "Amendment").   The   Amendment's   EDGAR   accession   number  is
0000932471-07-000016.  The Trust requests the withdrawal of the Amendment on the
grounds that it has no plans to proceed  with the offering of Signal  Shares for
the  Windsor  and  Windsor II Funds at this  time.  No  securities  were sold in
connection with this offering.

     Please  direct  any  communications  concerning  this  filing  to Arthur S.
Gabinet,  Principal and Assistant Secretary of The Vanguard Group, Inc. at (610)
503-5663.

Sincerely,


Arthur S. Gabinet
Principal and Assistant Secretary