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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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VALIC

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CTO operators monitor the status of nightly processing. In the event of a mainframe production abend, the

ticketing system pages VALIC personnel until the issue is resolved. Automated escalation procedures are in

place to make sure there is timely resolution of production issues. Incidents are properly reported, logged,

and resolved

(14.2)

.

Only CTO has access to the production job scheduler (CA-7). VALIC application programmers work with CTO

personnel to schedule the production jobs. In order to request a temporary override to a production job or job

schedule, the VALIC application programmer must fill out an authorized request form in the ticketing system tool

and obtain appropriate approval fromVALICManagement

(14.1)

.

Job Scheduling for Distributed Applications

Production processing is routine and controlled from the Back Office System server utilizing theWindows NT

Event Manager for automated scheduling/submission of batch jobs to generate reports, systemmonitoring,

personal identification number (PIN), and forms requests. The Group Retirement Application Support Department

is responsible for supporting production processing for the distributed applications.

For distributed applications, there are two jobs monitoring applications. In the event of a production problem,

the job monitoring software pages VALIC Information Technology personnel until the problem is resolved.

Two daily reports are sent to Application Managers via emails that describe the status of key production

jobs. The appropriate Application Manager will follow the job to resolution. Incidents are properly reported,

logged, and resolved

(14.3)

. In order to request a temporary override to a production job or job schedule, the

VALIC application programmer must fill out an authorized request form in the ticketing system tool and obtain

appropriate approval fromVALICManagement

(14.1)

.

For Unix, theAutoSys job scheduling software logs the successful and unsuccessful jobs using completion codes

that identifywhether a job ran to completion. In the event of a production failure, on-call lists retained by theGlobal

CommandCenter operations staff are used to contact the appropriate business unit staff for instructions on resolution.

Distributed systems applications job processing abends at FortWorth data center are identified, researched and

resolved. The Production BatchOperations support Group on-call programmer is notified of any failed jobs and is

responsible for providing restoration instructions. Production Batch failures are recorded automatically via incident

tickets. In addition, technician updates are recordedwithin the incident ticket of action taken to resolve the incident

(14.5)

. Job overrides, or changes to the scheduler follow the normal changemanagement process.

Job Scheduling for SAP

Batch processing in SAP includes daily load of data from various applications into SAP. SAP Daily Balancing

Reports that include batch loads into SAP are produced and reviewed daily. Any unbalanced general ledger

entries are corrected

(14.4)

.

Backup of Programs and Data Files

Backup of V-System

Backup of V-System is performed by CTO. CTO backs up the entire mainframe system using a DASD replication

process. The entire mainframe system is backed up instantaneously for disaster recovery purposes. This includes

V-System databases and files. IMS and DB2 databases are also backed up on a daily/weekly/monthly basis

depending on the system requirement. In addition to these backups, critical V-System data files are backed up

daily as part of the regularly scheduled cycle.

Monitoring procedures are in place to provide for the resolution of failed mainframe backup jobs. The on-call

programmer is notified of any failed jobs and is responsible for providing restoration instructions. Production

Batch failures are recorded automatically via incident tickets. Technician updates are recoded within the

incident ticket of action taken to resolve the incident

(15.1)

.

III. Description of the VALIC Defined Contribution Plan Administration System