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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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As mutual fund loan payments are made, principal and interest will be credited to the account. If a participant

takes a full distribution, the loan balance is offset and becomes a taxable event. If a participant dies, the loan is

deemed distributed and a tax form is issued to the estate of the participant.

Loans may be repaid in full at any time. If the loan is repaid in full before the end of the loan term, loan interest due

is prorated. IRS regulations require that payments be made at least quarterly. If payment is postmarked more than

30 days after the payment due date for the mutual fund product or received and applied to the account more than

90 days after the payment due date for the annuity product and mutual fund product, the loan is considered in

default and the remaining amount will be immediately due. The loan will be immediately defaulted and reported on

Form 1099R as a taxable distribution for federal tax purposes.

Bank-rejected checks or individual ACHs for loan payments are reversed out of the record keeping system

from each participant's affected account

(3.13)

. For plan sponsor ACH rejects, the plan sponsor is contacted to

resubmit the ACH. Quarterly reconciliations are performed and reviewed/approved by management to ensure

that all bank balances are reported accurately. Separate general ledger accounts are established for each bank

account. Cash account reconciliations are prepared and completed according to the AIG corporate account

reconciliation policy

(3.6)

.

Plan Administrator (Plan Sponsor) Directed Transfers

Plan sponsors may elect to transfer existing plan assets in addition to current remittances as plan sponsor

directed transfers. The transfer of existing assets requires significant planning prior to transfer. This often includes

coordination amongst the VALIC Advisor, Institutional Services, and other operations business units. VALIC follows

the appropriate Internal Revenue Code, Department of Labor (DOL), and Plan Document provisions with regard to

the transfer. In certain circumstances, VALICmay engage the plan sponsor in the participant notification process.

Processing instructions are provided in electronic format by the plan sponsor or other third party and must balance

to the assets transferred for the transfer to be executed.

III. Description of the VALIC Defined Contribution Plan Administration System