CSD-RT RFP Recordkeeping_Administration Services Response 3-

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.

Click

VALIC

.com 21

Group Product Selection

A new plan sponsor plan cannot be established on the record keeping system until the products that will be offered

within the plan are defined. For the majority of new plan setups, products are already defined on the record keeping

system so the process of loading the product to the new plan is a selection of the products from the applicable

product table. For a small percentage of new plan setups, the product has not been previously offered and it must

be added to the record keeping system before the new plan can be set up. Update access to the record keeping

system product code and vehicle tables is restricted. Product table modifications are made only when authorized

by the VALIC Underwriting Committee. An independent quality review is performed for plan sponsor-initiated

variable mutual fund adds, changes, and/or deletes to ensure the plan amendment/agreement or other plan

sponsor documentation and data input agrees

(1.4)

. New fund request forms are reviewed and set up in the record

keeping system and UVT. Reconciliation is performed and then reviewed by management

(1.5)

Fixed Interest Rates

VALIC is responsible for maintaining the fixed interest rates for the plan sponsor’s annuity line of business.

The interest rates are communicated to the business unit responsible for maintaining the tables by Actuarial.

Interest rates are input into non-production record keeping system tables (staging area) by a teammember with

appropriate security access. An independent review is performed for accuracy. Once reviewed and approved,

our Information Technology department then moves the interest rate tables into production. System access to

the interest rate tables is restricted to authorized teammembers. The Interest Crediting Committee reviews and

approves the interest crediting rates monthly

(10.6)

Contract Updates

For the annuity line of business, plan sponsors periodically renegotiate their VALIC product or service contracts.

After receiving approval from the VALIC Underwriting Committee and authorization from the plan sponsor, except

for contracts between the participant and VALIC, existing/new accounts are systematically updated in the record

keeping system to reflect the new negotiated product. In the case of a non-systematic upgrade, the new negotiated

product is added to existing/new accounts as the advisor meets individually with participants to complete the

appropriate paperwork. Authorization is not required by the plan sponsor for contracts between the participants

and VALIC unless the new negotiated product will be a plan sponsor product.

Plan Amendments

VALIC is responsible for entering plan amendment changes into the record keeping system. The plan sponsor

requests plan document amendments to change the plan administration parameters. VALIC sends the plan

sponsor any necessary amendments for the plan document. After confirming that the requested changes are

legal, feasible, and accurate, updates are made to the record keeping system. The plan sponsor may elect to send a

Summary Plan Description (SPD) describing the change to the plan participants.

III. Description of the VALIC Defined Contribution Plan Administration System