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.

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VALIC

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One-Time or Recurring Individual Contribution

Checks with paper backup are sent to the VALIC lockbox bank. In addition, Wire Transfers and Credit ACHs are

accepted at the VALIC concentration bank. Checks are periodically received directly at VALIC; however once

received, the checks are forwarded to the appropriate bank lockbox. In addition, participants with individual flexible

premium contracts may request VALIC to automatically withdrawmoney from their individual checking accounts.

Participant-Directed Capital Transfers

A participant may decide to move assets from another investment provider (vendor) to VALIC. The term “transfer”

is used to describe rollovers within an existing plan or the transfer of assets to a new plan. Internal Revenue Code

and Plan Documents determine if the participant can move all or a portion of their assets to a qualified plan. Assets

may be received via check or wire.

Transfer of Value and Asset Allocation Changes

Participants may execute trades such as transfers of value between funds or change investment options for future

contributions. When a participant requests a change through the available service channels, the request is verified

and the governing asset allocation mix is updated on the record keeping system. A transaction statement is sent

to the participant to confirm the change. An independent quality review is performed on manually entered Transfer

of Value (TOV) and Asset Allocation changes

(5.1)

Participants are authenticated within the VALIC Online application using a unique User ID and passwords that

are in accordance with AIG policy

(2.7, 4.5, 5.2, 6.4)

. Automated controls within the VALIC Online application

perform the following:

Automated controls within the

VALIC.com

application prevent invalid and incomplete TOV transactions

from being set up. Edits prevent depleting more than 100% on “From” funds and only available “To” funds

display. The sum of percentages allocated to “To” funds must equal 100%

(5.3)

Automated controls within the

VALIC.com

application prevent invalid and incomplete Asset Allocation

transactions from being set up. Only available funds are displayed and allocations must equal 100%

(5.4)

After an Asset Allocation or TOV transaction is successfully processed, VALIC uses a third-party vendor to send

transaction confirmations to participants. A transaction confirmation is sent to the participant by a third-party

vendor upon completion of Asset Allocations or TOV transactions. VALIC performs a daily reconciliation of

transaction confirmation counts sent fromVALIC to the third-party vendor and transaction confirmation counts

received from the third-party vendor

(5.5, 8.7)

. If the participant’s account records are not successfully updated

in the record keeping system during the nightly cycle, an error report is reviewed and corrections made and the

request processed

(5.6)

III. Description of the VALIC Defined Contribution Plan Administration System