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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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Group Mutual Fund Product

After transactions are processed through the record keeping system, a series of reconciliation and reporting

procedures are performed by Variable Product Accounting (VPA). This includes daily bank account reconciliation

of all investment related transactions and daily NSCC settlement. In addition, Accounting Operations handles all

cash management functions for the group mutual fund product which includes the following:

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Coordination of resolution with VALIC Operations of any open items on the record keeping system and

bank account reconciliation.

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Receipt and resolution of insufficient remittance/payment checks.

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Monitoring and clearing of disbursement errors.

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Production of manual checks.

As a management oversight, AIG Federal Savings Bank personnel reviewmonthly bank statements and open items.

Client Reporting

VALIC uses a third-party vendor to prepare and mail quarterly account statements to participants. A reconciliation

is performed of the number of participants sent to the vendor with the number of participants processed.

Additionally, the vendor sends VALIC electronic copies of the quarterly account statements which are maintained

in COLD

(8.3)

. VALIC audits a sample of quarterly account statements prior to authorizing the release of

statements for mailing or online viewing

(8.4), (10.5)

.

A number of plan reports are available to plan sponsors on

VALIC.com

or by mail. Reports are generally at the plan

level, for a monthly, quarterly, or annual period, to assist the plan sponsor in administering their retirement plans.

Annual regulatory reporting is also provided as required by state/federal regulations via mail, overnight delivery

service, or

VALIC.com

.

A report scheduler is utilized to systematically generate reports and track deliverables validating a timely delivery.

The GroupManager database is used to track plan report due dates to verify that the reports are generated

(8.1)

.

A systematic process is used to confirm that reports are provided in balance. Plan reports are reconciled and

corrected, if necessary, prior to making them available to the plan sponsors

(8.2)

.

Asset Management

Asset management represents the process and systems used in recording and monitoring of the investments

underlying the retirement plan accounts. For both the group mutual fund and the annuity products, asset

management is administered by VPA.

Plan sponsors select the investment vehicles amongst which participantsmay allocate their funds.Within an annuity

contract, VALIC offers investment choices fromfixed investment accounts to variable accounts or combination (fixed

and variable) contracts.Within the groupmutual fund platformVALIC typically offers a combination of mutual funds

and one or more fixed annuity or stable value options as permitted for the respective plan.

For both the annuity and group mutual fund products the available investment alternatives may also include a self-

directed brokerage account established with Charles Schwab (Schwab PCRA). Within an annuity contract, the plan

sponsor or other fiduciary may restrict the availability of one or more of the underlying investment options to the

participant. Within the group mutual fund platform, the plan fiduciary may select from a wide array of investment

options with which VALIC has, or can obtain, appropriate agreements. With the Schwab PCRA, participants

generally may select from among mutual funds not already available under the plan.

III. Description of the VALIC Defined Contribution Plan Administration System