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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Retirement Manager Inbound SPARK File Process Controls

The industry standard data file for sharing and aggregating plan disbursement information is called the SPARK file.

Amonthly audit of inbound SPARK files is performed to determine if any of the expected plan data is not received.

If any of the data is not received for active vendor plans on Retirement Manager, contact is made with the vendor

or plan sponsor regarding the delay

(11.5)

There are five separate disbursement reports available for the plan sponsor reflecting the data received in the file.

These reports consolidate the transactional data from various vendors which enables the plan sponsor to track and

monitor loan, hardship withdrawal or unforeseen emergency, in-service exchange, severance of employment, and

age-based distributions across vendors for individual participants. Retirement Manager aggregates disbursement

information from plan vendors due to loan, hardship withdrawal or unforeseen emergency, in-service exchange,

severance of employment, and age-based distributions and provides the plan sponsor or vendors with

consolidated disbursement reporting across vendors

(11.6)

A Retirement Manager Disbursement Eligibility module is available for plan sponsors using aggregated

disbursement information for 403(b) and 457(b) plans in Retirement Manager. Once activated Retirement

Manager calculates loan, hardship withdrawal or unforeseen emergency, in-service exchange, severance of

employment, and age-based distribution eligibility based on 403(b), 457(b), or specific plan restrictions. The

resulting certificate is used by the participant to request final approval from the designated vendor based on

individual contract restrictions

(11.7)

In cases where a 403(b) or 457(b) plan has multiple campus locations governed by the same plan document,

Retirement Manager can perform compliance services for disbursement requests and provide disbursement

reporting based on plan data under all campus locations

(11.8)

Retirement Manager Security Access Controls

Retirement Manager restricts the data at the plan sponsor, vendor, and participant level. Plan sponsors can only

access data belonging to their plans and cannot see any other plan information. Vendors can only view data for

participants that have enrolled with their company. Participants can only view their own personal data

(11.9)

Retirement Manager Outbound SPARK File Process Controls

Amonthly review is completed of all outbound SPARK files generated to external third parties to ensure that

the plan information is provided

(11.10)

. A review of confirmations produced by the system is used to validate

successful file completion for each service provider. This review also includes an internal approval process by

management.

III. Description of the VALIC Defined Contribution Plan Administration System