CORRESP 1 filename1.txt [SHIP LOGO VANGUARD/(R)/] P.O. Box 2600 Valley Forge,PA 19482-2600 610-669-1538 Judy_L_Gaines@vanguard.com October 17, 2007 Christian Sandoe, Esq. U.S. Securities & Exchange Commission via electronic filing 100 F Street, N.E. Washington, DC 20549 RE: VANGUARD BOND INDEX FUNDS Dear Mr. Sandoe, The following summarizes our discussion of this afternoon regarding comments to Post-effective Amendment No. 46 of Vanguard Bond Index Funds' registration statement. The Post-Effective Amendment was filed on August 30, 2007. The comments pertain to Vanguard Inflation-Protected Securities Fund. COMMENT 1: PROSPECTUS - PRIMARY RISKS ---------------------------------------------------- COMMENT: Since the Fund's Primary Investment Strategies reference investment in corporations, credit risk should be included in Primary Risks. RESPONSE: The Fund invests in inflation-indexed bonds issued "by the U.S. government, its agencies and instrumentalities, and corporations," meaning corporations of the U.S. government, rather than "business" corporations. Examples of the government corporations in which the Fund invests are FNMA and GNMA. Per the Fund's most recent semiannual report, 99.8% of the Fund's assets were invested in U.S. Treasury Inflation-Indexed notes, and the Fund had an average credit quality of Aaa. For all of these reasons, we are satisfied that we currently disclose the relevant primary risks, and we plan to leave the current disclosure unchanged. COMMENT 2: PROSPECTUS - FINANCIAL INFORMATION ---------------------------------------------------- COMMENT: Will Vanguard's 485(b) filing include updated financials? RESPONSE: Yes, our 485(b) filing will include updated financials. COMMENT 3: PROSPECTUS - PLAIN TALK ABOUT THE FUND'S PORTFOLIO MANAGERS ------------------------------------------------------------------------------ COMMENT: If the Fund has more than one Portfolio Manager, please specify the role played by each in managing the Fund's assets. RESPONSE: We have discussed the comment with the Portfolio Managers of the Fund, and they have confirmed that the existing disclosure whereby the PMs are referred to as "co-managers" is an accurate description of their roles. The PMs work together in managing fund assets, sharing in the determination of strategies and risk exposures, and placing trades on behalf of the Fund. Furthermore, we believe that our existing disclosure satisfies the requirements of Item 5(a)(2) of Form N-1A. Accordingly, we do not plan to amend the disclosure. COMMENT 4: SAI - PORTFOLIO TRANSACTIONS ---------------------------------------------- COMMENT: Please edit the first sentence in the second full paragraph on Page B-39 to clarify which funds did not pay any brokerage commissions during their past three fiscal years. RESPONSE: We will edit the sentence as requested. COMMENT 5: TANDY REQUIREMENTS ------------------------------------ As required by the SEC, the Fund acknowledges that: o The Fund is responsible for the adequacy and accuracy of the disclosure in the filing. o Staff comments or changes in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing. o The Fund may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact me at (610) 669-1538 with any questions or comments regarding the above responses. Thank you. Sincerely, Judith L. Gaines Associate Counsel Securities Regulation, Legal Department