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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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VALIC

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Descriptions of the VALIC business units that support the VALIC Defined Contribution Plan processing are below:

Business Units

Responsibilities

Contact Center

Provides phone and participant transaction services.

Client Contribution Services

Processes payroll deductions.

Institutional Services

Provides full service group plan administrative services, and also includes the VALIC

Custodial Manager, responsible for oversight of the role of VALIC as an IRS-approved

non-bank custodian for a portion of the Defined Contribution Plan mutual fund

custodial accounts. (Custodial functions generally are incorporated into many of the

functions described below.)

Client Transaction Services

Processes financial and non-financial transactions.

Advisors

Assists plan sponsors and participants by planning and coordinating completion of

the appropriate paperwork for account setup.

Operations Support

Responsible for mail handling, document management, contract issue, transaction

confirms, account statements and interest rate table maintenance.

AIG Shared Services (AIGSS)

AIGSS located in Manila, Philippines, a subsidiary of American General Life Insurance

Company, an AIG subsidiary, processes distributions (one form of benefit payments),

payroll contributions for VALIC variable annuities and Document Management

image/indexing with oversight from the management at the VALIC Amarillo, TX

service center.

AIG Federal Savings Bank

(AIG FSB)

AIG FSB, an AIG subsidiary and VALIC affiliate, is a federally chartered savings

bank. AIG FSB serves as the trustee or custodian for the benefit of retirement

plan participants in employer-sponsored tax-qualified (e.g., 403(b), 401(k)) and

nonqualified (e.g., 457(f)) plans, pursuant to an agreement with VRSCO, as well

as custodial or trust agreements with individual plan sponsors. In its role as a

nondiscretionary, directed trustee or custodian, AIG FSB is responsible for receiving,

safeguarding and distributing retirement plan assets.

Testing Shared Services Utility

(TSSU)

Provides quality assurance services (QA testing) for VALIC application development

and support. TSSU engages other global delivery partners to provide QA testing

support across AIG.

The following functions within VALIC provide ancillary support to the VALIC business units noted above:

Business Units

Responsibilities

Actuary

Provides actuarial services and reserve calculations for financial support.

Accounting Operations

Responsible for supporting and recording incoming/outgoing cash via wire transfer,

lockbox banks, disbursement processing, bank reconciliation, and participant tax

reporting.

Legal

Provides legal counsel in support of the operations including monitoring state and

federal legislative and regulatory activity, compliance with federal securities laws

and regulations (including the FINRA), and state insurance laws and regulations.

III. Description of the VALIC Defined Contribution Plan Administration System