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This report is intended for use by the management of the Variable Annuity Life Insurance Company ("VALIC") and its subsidiaries.

VALIC Retirement Services Company ("VRSCO") and VALIC Financial Advisors, Inc. ("VFA"), its user entities, and the independent

auditors of its user entities, and is not intended and should not be used by anyone other than these specified parties.

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III. Description of the VALIC Defined Contribution Plan Administration System

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VALIC

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Overview of operations and services provided

Overview of the Organization

The Variable Annuity Life Insurance Company (VALIC) is an indirect wholly-owned subsidiary of the American

International Group, Inc. (AIG). VALIC Retirement Services Company (VRSCO) is a transfer agent registered with

the U.S. Securities and Exchange Commission (SEC) and a wholly-owned subsidiary of VALIC. The Operations

Division of VALIC supports the VALIC Defined Contribution Plan processing and is made up of six business units:

VALIC Contact Center, VALIC Client Contribution Services, VALIC Institutional Services, VALIC Client Transaction

Services, VALIC Advisors, and VALIC Operations Support. Note that VALIC agents are registered representatives

of VALIC Financial Advisors, Inc. (VFA), an SEC-registered broker/dealer and investment adviser and a wholly-

owned subsidiary of VALIC.

Unless otherwise specified and for the purposes of this report, VALIC and its subsidiaries are collectively referred

to as VALIC, or the Company.

Figure 1 below illustrates the relationship of VALIC in the corporate structure and the Operations Division, which

supports the VALIC Defined Contribution Plan Administration.

AIG

VALIC

VRSCO

VFA

VALIC

Contact

Center

VALIC

Client

Contribution

Services

VALIC

Client

Transaction

Services

VALIC

Institutional

Services

VALIC

Operations

Support

Operations

Division

VALIC

Advisors

Figure 1: VALIC Organizational Chart