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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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Incoming participant callers to the Contact Center are verified before providing any participant or account specific

information to the caller or performing any transactions for the caller

(2.5, 4.4, 5.7, 6.5)

. The following information

must be verified before releasing any information: participant name, Social Security (SSN) or account number and

date of birth. Effective September 1, 2016, the Contact Center adopted Computer Telephony Integration (CTI)

technology that provides callers the option of self-identifying.

If the caller opts to key in their SSN, the CTI technology will present the information to the CSR in a screen pop

providing the CSR with the name matching the SSN input by the caller. CSRs validate this name with that of caller

and if it matches, CSRs then ask for their date of birth. Once the date of birth is confirmed, CSRs deem the caller

authenticated and proceed with the call.

If, however, the caller indicates the name is incorrect, the CSR will revert to authenticating the caller by asking the

caller their name, SSN or account number and date of birth.

* Please Note: Callers can bypass the CTI option. If bypassed, callers will be authenticated by CSR asking for

caller's name, SSN or account number and date of birth.

VALIC Document Management ensures transaction requests are imaged into AWD. The incoming mail and

imaging area is located in a secured room. Only authorized individuals have access to this room via the security

card reader system. A quality control review is performed to ensure that a bar coded splitter sheet is placed

between each document that identifies the work type before scanning. An index file of the scanned documents

is routed to AWD for processing. The job that routes the image file to AWD is monitored for processing

(2.8,

3.15, 4.6, 5.8, 6.6)

. Complaints are monitored by management and the Consumer Affairs Department

(2.4,

3.16, 4.7, 5.9, 6.7)

. VALIC manages participant record keeping with a systematic workflow methodology utilizing

AWD. Within this process, participant requests are imaged to route the work to the respective business unit,

which manages each transaction type from initiation of processing through quality review to record retention

by using AWD. Management reviews reports from AWD to balance workloads and maintain overall operational

standards.

All transaction instructions must be in good order prior to processing. This requires that all paperwork and

processing instructions contain the necessary information to initiate the transaction. The VALIC advisors assist

participants and plan sponsors by coordinating completion of the appropriate paperwork. Transactions are input

into the record keeping system based upon complete instructions. Transactions that error in the record keeping

system are researched and resolved.

Account Changes

Non-monetary data changes are reviewed to confirm they are in good order prior to processing

(2.1)

.

A confirmation letter is generated to the participant upon completion of the transaction. Confirmation

letters are stored and tested on a sample basis for completion and notification to the participant. For any

confirmation letters that are not stored, VALIC performs a daily reconciliation of confirmation counts

between the transaction data VALIC sends to the third-party vendor and the number of letters the third-

party vendor mails.

(2.2, 2.3, 8.5, 8.6)

Through May 6, 2016, a report was generated for nonmonetary participant updates resulting from an internal

rollover request which was reviewed and approved by new business management

(2.6)

. BeginningMay 9, 2016

and upon implementing a new client data change tool, updates follow the same process as all other non-

monetary data changes.

III. Description of the VALIC Defined Contribution Plan Administration System