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Prepared for Springfield R-XII School District

27

Our lead attorney has more than 20 years’ experience working directly with plans and was a

contributing author to the Panel’s 403(b) Answer Book from 1995 until 2011.

VALIC also retains a major Washington, D.C. law firm as outside legal counsel to assist in

tax matters. As well, VALIC’s government affairs department is committed to supporting

legislative efforts to retain tax features associated with retirement programs for

governmental, healthcare, educational and tax-exempt organizations.

Please note that VALIC's law division does not render legal advice to our client groups.

However, we are happy to offer, at no additional cost, collaborative (non-advisory) contacts

between your legal counsel and ours to discuss plan matters (deemed appropriate by you

and VALIC) within the context of our ongoing relationship.

Regulatory and Legislative Changes

VALIC uses several methods to notify clients of legislative or regulatory changes that may

affect their programs. First, our newsletter provides updates on such changes periodically.

This publication is sent to clients, as well as all field offices and relationship managers.

Second, our extensive network of local financial advisors, district vice presidents and

relationship managers is available to discuss any pending or enacted legislation. Finally,

VALIC's website features articles and webcasts on the most current news, legislation and

regulatory updates that may affect retirement programs.

VALIC has dedicated a team of professionals to monitor our systems and our clients' plans

to assist the plan sponsor with compliance with changing rules and regulations. Additionally,

law division personnel support the system review process to ensure continued compliance.

VALIC also actively participates in design and testing of system enhancements made

necessary by regulatory changes.

Because our plan administration professionals are highly trained in the intricacies of plan

design and compliance, they can assist the plan sponsor with these issues.

Plan Compliance

VALIC administers the plan document according to its terms, and updates our plan

documents to reflect legislative or regulatory changes, enabling VALIC to monitor

compliance and help the plan sponsor meet federal regulations with respect to its plan. We

also perform periodic audits to verify that all necessary forms and authorizations are on file.

14.Describe the support you provide in the event of a plan audit. Please specifically

identify any costs associated with these services in the Fees and Expenses portion of

your response.

In the event that your retirement program is selected for examination by the IRS, VALIC's

standard audit package can ensure that a prompt response is provided. If circumstances

lead to compliance failures, our Audits Task Force has knowledge and experience in

assisting clients with corrections under the Employee Plans Compliance Resolution System

(EPCRS) published by the IRS. We are happy to assist you and your legal counsel in

implementing any necessary corrective activity.