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Report on the VALIC Description of its Defined Contribution Plan

Distribution System and on the Suitability of the Design and Operating

Effectiveness of its Controls throughout the period October 1, 2015 to

September 30, 2016

Prepared pursuant to statement on standards

for attestation engagements (SSAE) No. 16

The Report on the VALIC Description of its system and on the Suitability of the

Design and Operating Effectiveness of Its Controls is confidential. The report is

intended solely for use by the management of VALIC, its user entities, and the

independent auditors of its user entities.