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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Control objectives and related controls

The VALIC control objectives and related controls are included in Section IV of this report, (VALIC Control

Objectives, Controls, and PricewaterhouseCoopers LLP’s tests of operating effectiveness and results of tests),

to eliminate the redundancy that would result from listing them in this section and repeating them in Section IV.

Although the control objectives and related controls are included in Section IV, they are an integral part of the

VALIC description of controls.

Complementary User Entity Controls

The processing of transactions performed by VALIC, for participants and controls at VALIC, cover only a portion

of the overall internal control environment. It is not feasible for the control objectives relating to the processing

of transactions to be solely achieved by VALIC. Therefore, each participant’s internal control must be evaluated

in conjunction with the controls of VALIC and testing summarized in Section IV of this report (VALIC Control

Objectives, Controls, and PricewaterhouseCoopers LLP’s tests of operating effectiveness and results of tests).

This section highlights those internal control responsibilities VALIC believes should be present at each participant

and has considered in developing its controls reported on herein. Each participant must evaluate its own internal

control to determine if the following controls are in place. Furthermore, this list does not purport to be and is not

a complete listing of the controls that provide a basis for the assertions underlying the financial statements of

participants.

Contract/Plan Administration and Client Record Keeping (Control Objectives 1, 2, 3, 4, 5, 6, and 7)

Each retirement plan is responsible for establishing controls to confirm that the following information sent to

VALIC is complete, properly authorized, and in accordance with its plan’s requirements and criteria and provided in

a timely manner:

Information for initial setup of plan and participant accounts

Requests to modify participant information

Written procedures for administering Policy Loans (if applicable) and

Qualified Domestic Relations Orders

Remittances and detailed allocation instructions to VALIC

Benefit payment and loan requests

Compliance information

Operational information

The plan sponsor is responsible for reconciling total contributions (deposits) made by plan sponsors to total

contributions recorded in the plan statement.

III. Description of the VALIC Defined Contribution Plan Administration System