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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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Charges

VALICmay assess charges to plan sponsors /participants for services such as account maintenance charges,

separate account charges, administrative fees, short term trading fees and/or transaction fees, such as loan

initiation fees. These fees are mutually agreed-upon fees found in the applicable legal documents for each plan.

The record keeping system calculates charges, based on the parameters in the plan sponsor’s agreement or

contract. The charge reimburses VALIC for administrative expenses associated with providing plan sponsor

services and participant record keeping. Applicable charges that are deducted from participant accounts are

summarized in account statements that are sent to the participants. If the plan sponsor has agreed to pay the

charges, rather than deduct them from participant accounts, the charges are sent in the form of an invoice to the

plan sponsor.

The record keeping system as reflected in the appropriate legal documentation agreed upon by the plan sponsor

calculates fees assessed on certain transactions such as loans.

For the annuity line of business, separate account charges are also calculated based on the parameters in the plan

sponsor’s group annuity contract. Separate account charges include the total of a mortality and expense (M&E)

fee and an administration fee. These charges are factored into the unit value calculation. The resultant unit value

is applied to units held to determine account balances for plans and participants who have invested in variable

investment options.

Participant Record Keeping

The methods for participants to initiate transactions with VALIC are illustrated below.

III. Description of the VALIC Defined Contribution Plan Administration System

Mail or Fax

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Participant Account Setup

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IRA/NQDA Contributions

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Rollovers/ Transfers

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Transfer of Value

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Asset Allocation Changes

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Loans

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Benefits Payments

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Address Changes

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Beneficiary Changes

Interactive Voice Response

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Transfer of Value

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Asset Allocation Changes

Internet

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Transfer of Value

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Asset Allocation Changes

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Loans

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Address Changes

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Partial Withdrawals

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Beneficiary Changes

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Enrollment

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Banking Maintenance

(EFT or ACH)

Contact Center

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Transfer of Value

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Asset Allocation Changes

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Plan Enrollment

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Banking Maintenance

(EFT or ACH)

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Loans

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Partial Withdrawals

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Address Changes

VALIC