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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Development and test environments are available to test changes. Changes are tested by the AIG business unit (if

applicable) and migrated into production by a CTO assignee from the assignment group designated in the change

ticket. Infrastructure changes performed by CTO are tested and approved

(12.9, 14.6)

SAP — Standard Change Management Process

The SAP Solutions Center Change Management Process governs the approval and migration of all SAP related

change requests. All SAP change requests are logged and are then submitted to an appropriate technical resource.

The technical resource then creates a request to create Correction Documents in SolutionManager to Change

Management (henceforth referred to as CM team) team. The CM team approves the change request in Solution

Manager and creates the required corresponding correction document. Once the correction document has been

assigned to the team lead, the team lead creates transports against these correction documents and assigns the

transport/task to the resource working on this change. Development of SAP changes is completed by developers

and configurators within the development environment, unit tested, and then moved to the Quality Assurance

(QA) environment for completing system integration and user acceptance testing. Once QA testing has been

approved, and validated in the QA environment by the QAManager, changes are approved before moving to the

production environment. SAP developer access to the production environment is appropriately controlled and

restricted

(12.6, 13.2)

. Test plans and test results are documented and signed off by authorized employees for

SAP changes

(12.7)

. All required approvals for SAP changes (including business and technology) are obtained and

documented prior to migration of the change into the production environment

(12.8)

Changes to UNIX (SAP operating system) generally consist of patches or fixes. A change request ticket is opened

in the Service Now systemwhere supporting evidence is maintained. Changes to SAP's operating system are

tested and approved prior to loading into the production environment

(12.9, 14.6)

. Testing of the change is

performed on an as needed basis. Once the change has been approved it is implemented into production.

SAP — Emergency Move Process

The emergency move process is the same as the standard move process but is performed in an expedited

manner with required approvals being allowed to occur after an emergency change has already been moved to

production. The components being moved to production for emergency changes still migrate physically through

the development and quality assurance environments and require the same documentation and sign-offs required

for normal changes. AIG (ADM) standards provide seven days’ time after production implementation to complete

any missing documentation.

III. Description of the VALIC Defined Contribution Plan Administration System