February 24, 1994
Securities & Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549
Re: Rule 24f-2 Notice for Vanguard Index Trust
File No. 2-56846
Gentlemen:
Pursuant to Rule 24f-2 under the Investment Company Act of 1940, Vanguard
Index Trust (the "Fund"), hereby files its Rule 24f-2 Notice for the fiscal
year ended December 31, 1993. A wire transfer in the amount of $574,510.16
in payment of the registration fee due for the Fund's Rule 24f-2 filing has
been sent to the lockbox at Mellon Bank in Pittsburgh for deposit to the
Securities and Exchange Commission's account number 910-8739.
1. At the beginning of the fiscal year, the Fund had the following
securities registered under the Securities Act of 1933 (the "1933 Act")
other than pursuant to Rule 24f-2, but which remained unsold:
Aggregate Offering
Price of Shares on
which Registration
Name of Securities Number of Shares Fee was Paid
Shares of Beneficial
Interest (No Par Value)
Extended Market Portfolio None None
500 Portfolio None None
Value Portfolio None None
Growth Portfolio None None
Total Stock Market Portfolio None None
2. During the fiscal year the Fund registered the following securities
under the 1933 Act other than pursuant to Rule 24f-2:
Aggregate Offering
Price of Shares on
which Registration
Name of Securities Number of Shares Fee was Paid
Shares of Beneficial
Interest (No Par Value)
Extended Market Portfolio None None
500 Portfolio None None
Value Portfolio None None
Growth Portfolio None None
Total Stock Market Portfolio None None
3. The number and the aggregate sales price of the Fund sold during the
fiscal year was as follows:
Name of Securities Number of Shares Aggregate Sales Price
Shares of Beneficial
Interest (No Par Value)
Extended Market Portfolio 20,530,085 $ 388,872,435
500 Portfolio 66,437,963 2,820,284,242
Value Portfolio 17,152,255 195,121,693
Growth Portfolio 5,216,661 52,370,583
Total Stock Market Portfolio 25,030,030 280,975,854
Totals 134,366,994 $3,737,624,807
4. The number and aggregate sales price of shares of the Fund sold during
the fiscal year in reliance pursuant to Rule 24f-2 was as follows (See
footnote attached as Exhibit A hereto):
Name of Securities Number of Shares Aggregate Sales Price
Shares of Beneficial
Interest (No Par Value)
Extended Market Portfolio 20,530,085 $ 388,872,435
500 Portfolio 66,437,963 2,820,284,242
Value Portfolio 17,152,255 195,121,693
Growth Portfolio 5,216,661 52,370,583
Total Stock Market Portfolio 25,030,030 280,975,854
Totals 134,366,994 $3,737,624,807
Enclosed is an opinion of counsel (Exhibit B) indicating that the
securities sold in reliance upon Rule 24f-2 were legally issued, fully paid
and non-assessable.
Very truly yours,
VANGUARD INDEX TRUST
BY: (Raymond J. Klapinsky)
Secretary
RJK:fms
EXHIBIT "A"
FOOTNOTE TO RULE 24F2 NOTICE OF
VANGUARD INDEX TRUST
The calculation of the registration fee pursuant to subsction (c) of Rule
24f-2 is set forth below. The Fund did not apply any redemptions or
repurchases which took place during the fiscal year to the registration of
any securities pursuant to Section 24(e) of the Investment Company Act.
<TABLE>
<CAPTION>
(a) (b) (c) (d)
Aggregate Sales Aggregate Price of Aggregate Sales Fee Payable
Price of Securities Securities Redeemed Price on which pursuant to
Sold in Reliance or Repurchased fee will be based Section 6(b)
upon Rule 24f-2 During Fiscal Year (a minus b) of 1933 Act
<S> <C> <C> <C> <C>
Vanguard Index Trust
Shares of Beneficial
Interest (No Par VAlue)
Extended Market Portfolio 388,872,435 136,008,071 -- --
500 Portfolio 2,820,284,242 1,784,888,756 -- --
Value Portfolo 195,121,693 42,723,346 -- --
Growth Portfolio 52,370,583 23,781,951 -- --
Total Stock Market Portfolio 280,975,854 84,154,886 -- --
Totals $3,737,624,807 $2,071,557,010 $1,666,067,797 $574,510.16
</TABLE>
EXHIBIT "B"
February 24, 1994
Vanguard Index Trust
1300 Morris Drive, P.O. Box 876
Valley Forge, PA 19482
Gentlemen:
Vanguard Index Trust (the "Fund") is a business trust established under
Pennsylvania law under a Declaration of Trust dated December 31, 1975. I
have acted as legal counsel to the Fund since its initial registration as
an open-end management investment company under the Investment Company Act
of 1940 ("1940 Act"), as amended. It is in my capacity as counsel to the
Fund that I am furnishing you this opinion.
I have examined the Fund's: (1) Declaration of Trust and amendments
thereto; (2) minutes of the meetings of shareholders and Trustees; (3)
Notification of Registration on Form N-8A under the 1940 Act; (4)
Registration Statement on Form N-1A under the Securities Act of 1933 ("1933
Act") and 1940 Act, and all amendments thereto; and (5) all other relevant
documents and records, as well as the procedures and requirements relative
to the issuance and sale of the Fund's shares of beneficial interest
("shares").
Under Article V Section 5.1 of the Declaration of Trust, as amended to
date, the Fund is legally authorized to issue an unlimited number of
shares, without par value, from an unlimited number of series
("Portfolios") of shares. On December 31, 1993, (the end of the Fund's
fiscal year), the Fund had 47,768,420 shares of the Extended Market
Portfolio, 188,757,876 shares of the 500 Portfolio, 16,197,510 shares of
the Value Portfolio, 4,964,135 shares of the Growth Portfolio, and
43,824.943 shares of the Total Stock Market Portfolio issued and
outstanding.
My examination also disclosed the following information:
1. On January 1, 1993, (the beginning of the Fund's last fiscal year),
the Fund had no shares registered under the 1933 Act other than pursuant to
Rule 24f-2 of the 1940 Act, but which remained unsold on that date.
2. During the fiscal year ended December 31, 1993, the Fund did not
register any shares under the 1933 Act other than pursuant to Rule 24f-2.
3. During the fiscal year ended December 31, 1993, the Fund sold
20,530,085 shares at an aggregate sales price of $388,872,435 from the
Extended Market Portfolio; 66,437,963 shares at an aggregate sales price of
$2,820,284,242 from the 500 Portfolio; 17,152,255 shares at aggregate sales
price of $195,121,693 from the Value Portfolio; 5,216,661 shares at an
aggregate sales price of $52,370,583 from the Growth Portfolio; and
25,030,030 shares at an aggregate sales price of $280,975,854 from the
Total Stock Market Portfolio in reliance upon registration pursuant to Rule
24f-2 of the 1940 Act. During the same fiscal year, the Fund redeemed
7,407,348 shares at an aggregate redemption price of $136,008,071 from the
Extended Market Portfolio; 41,843,814 shares at an aggregate redemption
price of $1,784,888,756 from the 500 Portfolio; 3,680,028 shares at an
aggregate redemption price of $42,723,346 from the Value Portfolio;
2,392,736 shares at an aggregate redemption price of $23,781,951 from the
Growth Portfolio; and 7,434,467 shares at an aggregate redemption price of
$84,154,886 from the Total Stock Market Portfolio.
You have instructed me to file, on behalf of the Fund, a Notice pursuant to
Rule 24f-2 of the 1940 Act, for the purpose of registering, under the 1933
Act, the combined total of 134,366.994 shares which were sold by the Fund
during the fiscal year in reliance upon Rule 24f-2 of the 1940 Act.
Based upon the foregoing information and my examination, it is my opinion
that:
1. The Fund is a validly organized and subsisting trust of the
Commonwealth of Pennsylvania authorized to issue an unlimited number of
shares, without par value, from an unlimited number of Portfolios of
shares;
2. The proposed registration of the combined total of 134,366,994 shares
of the Fund in reliance upon Rule 24f-2 of the 1940 Act is proper;
3. Such shares, which were issued for a consideration deemed by the
Trustees to be consistent with the Declaration of Trust, are legally
authorized and issued, fully paid, and non-assessable; and
4. The holders of such shares have the rights provided with respect to
such holdings by the Declaration of Trust, as amended.
I hereby consent to the use of this opinion as an Exhibit to the Rule 24f-2
Notice to be filed on behalf of the Fund, covering the registration of such
shares under the 1933 Act, and to the applications and registration
statements, and amendments thereto, filed in accordance with the securities
laws of the states in which shares of the Fund which are offered. I
further consent to reference in the Prospectus of the Fund to the fact that
this opinion concerning the legality of the issue has been rendered by me.
Very truly yours,
BY: (Raymond J. Klapinsky)
RJK:fms
