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.

Click

VALIC

.com 36

Retirement Manager

Retirement Manager Implementation

A quality review is completed to validate that Retirement Manager is set up according to the information provided

by the employer regarding the plan and the approved vendors

(11.1)

Retirement Manager Limit Calculations

Retirement Manager will monitor plan limits and provide individual limit reporting for participants that are

expected to exceed or have exceeded their individual limits.

If a participant has already contributed more than their annual contribution limit, then this participant is reported

to the plan sponsor on the Exceeds Report.

A Retirement Manager Contribution Limit Enforcement module is available for selected plan sponsors with an IRC

403(b), 401(k), 401(a)/403(a), 414(h) and 457(b) plan types. Retirement Manager proactively reduces or stops

deferral amounts for participants to prevent excess contributions

(11.2)

A Retirement Manager HardshipWithdrawal Enforcement module is available for selected plan sponsors with

IRC 403(b) plan type. Retirement Manager suspends elective contributions for a period of six months or more if

designated by the plan

(11.3)

With regard to Contribution Limits and HardshipWithdrawal Enforcement modules, funds are released to the

vendor or returned to the plan sponsor as instructed

(11.4)

Retirement Manager Disbursement Reporting

For plan sponsors that elect plan disbursement reporting with 403(b) and 457(b) plan types, Retirement Manager

provides for either a vendor or a plan sponsor to send a file containing transactional data for loans, hardship

withdrawals or unforeseen emergency, in-service exchanges, severance of employment, and age-based in-service

distributions at the plan level. These files will be primarily transmitted to Retirement Manager from vendors on a

monthly basis.

III. Description of the VALIC Defined Contribution Plan Administration System