Form 485BXT VANGUARD WHITEHALL FUNDS

This Post - Effective Amendment No. 79 under the Securities Act of 1933, as amended (Amendment No. 81 under the Investment Company Act of 1940, as amended) to the registration statement on Form N - 1A (the Registration Statement ) of Vanguard Whitehall Funds (the Trust ) is being filed pursuant to paragraph (b)(1)(iii) of Rule 485 under the Securities Act of 1933 solely for the purpose of delaying, until February 5, 2019, the pending effective date of the Trust s 78 th Post - Effective Amendment.

By way of further background, Post - Effective Amendment No. 78 was filed under Rule 485(a)(1) on November 19, 2018 for the purposes of: (1) adding a new Admiral share class to Vanguard High Dividend Yield Index Fund and (2) effecting a number of non - material editorial changes. Post- Effective Amendment No. 78 originally requested that the Amendment become effective 60 days after filing, pursuant to the requirements of Rule 485(a)(1) .

This Post - Effective Amendment No. 79 incorporates by reference the information contained in Parts A, B, and C of Post - Effective Amendment No. 78 to the Trust s Registration Statement.

Pursuant to the requirements of the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant has duly caused this Registration Statement to be signed on its behalf by the undersigned, thereunto duly authorized, in the Town of Valley Forge and the Commonwealth of Pennsylvania, on the 17th day of January, 2019.

Pursuant to the requirements of the Securities Act of 1933, this Post-Effective Amendment to the Registration Statement has been signed below by the following persons in the capacities and on the date indicated:

*By: /s/ Anne E. Robinson

Anne E. Robinson, pursuant to a Power of Attorney filed on January 18, 2018 see File Number 33-32216, Incorporated by Reference.

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