Form 485BXT VANGUARD WHITEHALL FUNDS

Explanatory Note

This Post-Effective Amendment No. 69 under the Securities Act of 1933, as amended (the “Securities Act”) (Amendment No. 71 under the Investment Company Act of 1940, as amended (the “1940 Act”) 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 solely for the purpose of delaying, until February 23, 2017, the pending effective date of the Trust’s 67^th Post-Effective Amendment. By way of further background:

• Post-Effective Amendment No. 67 was filed under Rule 485(a)(1)(iii) on November 30, 2016, for the purpose of: (1) adding a purchase and a redemption fee of 0.25%, respectively, on the conventional share classes (Investor Shares and Admiral Shares) to the Vanguard International High Dividend Yield Index Fund and Vanguard International Dividend Appreciation Index Fund, each a series of the Trust; and (2) to effect a number of non-material changes. Post-Effective Amendment No. 67 originally requested that the Amendment become effective January 29, 2017.

This Post-Effective Amendment No. 69 incorporates by reference the information contained in Parts A, B, and C of Post-Effective Amendment No. 67 to the Registrant’s Registration Statement.

SIGNATURES

Pursuant to the requirements of the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant hereby certifies that it meets all requirements for effectiveness of this Registration Statement pursuant to Rule 485(b) under the Securities Act of 1933 and 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 27th day of January, 2017.

VANGUARD WHITEHALL FUNDS
BY:___________/s/ F. William Mc Nabb III*_________

F. William McNabb III

Chairman and Chief Executive Officer

     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 October 4, 2016, see File Number 33-32548, Incorporated by Reference.