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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

.com 14

Business Units

Responsibilities

Information Technology

Serves as a liaison between business units and technology service providers and performs

business application development, quality assurance (QA) testing, implementation,

security andmaintenance activities for all internally based technology platforms.

Financial Reporting

Responsible for the preparation of financial statements and disclosures, monitoring

and verification of compliance with federal securities laws, analysis of the financial

activity and remitting taxes withheld to appropriate authorities required for the

separate accounts.

Variable Product Accounting and

Reporting (VPA)

Responsible for the collection, reconciliation and communication of processed trade

activity to the appropriate fund companies. This accounting group initiates and

verifies the settlement of those trades and also the reconciliation of outstanding

shares between the fund companies and the record keeping system.

Chief Technology Office (CTO)

Provides operating system and server support for mainframe and distributed systems

for AIG Life and Retirement companies which includes VALIC. CTO supports facilities

management; security access administration, batch processing and daily operations

tasks and support. CTO is also responsible for business continuity which includes

back-up and restore of all mainframe and distributed applications for VALIC .

Third-Party Services used by VALIC

VALIC uses third-party service vendors to achieve operating efficiency and obtain specific market expertise.

That includes technology services, lockbox, wire transfer, EFT, printing and mailing. (This report and related

control environment descriptions do not address the controls and related control objectives of these Third-

Party Service vendors.)

The VALIC principal third-party service vendors are described below:

Lockbox

Vendors include JPMorgan Chase Bank via hardcopy checks, e-Remit, Automated

Clearing House (ACH) Debit, Northern Trust Company (NTC) and Bank of America

(BoA).

Wire Transfer and Electronic

Fund Transfer (EFT)

The Bank of New York Mellon (BoNY).

Confirmations and Account

Statement Printing and Mailing

Vendors include Fiserv for participant account statements and HOV Services for

financial and non-financial confirmations.

Application Support/

Development and DBA Services

Mphasis provides application database admin support for all of the VALIC mainframe

applications which are using IMS/DB2 database. Mphasis provides application

support/development database services, database recovery management, disaster

recovery management and database reports.

SunGard

– Relius Government Forms

Web based portal utilized to generate required governmental reporting of Form

5500 and related schedules including Form 8955-SSA for ERISA plans.

SunGard Corbel Plan Documents

Web based portal utilized to generate written documents for various plan types that

set forth the terms of the plan.

Actuarial Systems Corporation

(ASC)

Software utilized to perform required non-discrimination testing for ERISA plans.

III. Description of the VALIC Defined Contribution Plan Administration System