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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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Certain transactions will automatically generate a confirmation that is generally sent to the plan participant.

Certain participants elect to have confirmations mailed directly to the plan sponsor for those confirmations; the

plan sponsor is responsible for the timely distribution of these confirmations to the participants for their review

and for communicating any discrepancies noted to VALIC on a timely basis.

Each plan sponsor is responsible for notifying VALIC of any changes to organizational structure or requested

changes to the plan.

Client Reporting (Control Objective 8)

On a quarterly basis, participant level statements for defined contribution plans are mailed directly to the

participants or bulk mailed to the plan sponsor. Also, on a quarterly and/or annual basis, plan level reports are

distributed to the plan sponsor for review. The plan sponsor is responsible for:

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Distributing bulk mailed statements to the participants for their review

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Reviewing the plan level reports for completeness and accuracy

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Communicating any discrepancies noted to VALIC on a timely basis

Upon request by the plan sponsor, monthly, quarterly, or annual reports detailing processing completed for the

period are sent to plan sponsor for review. The plan sponsor is responsible for comparing this information to its

records and notifying VALIC of any discrepancies on a timely basis.

Compliance and Regulatory Support (Control Objective 11)

Plan sponsors are responsible for providing current, complete and accurate information to VALIC. This includes,

but is not limited to, the following:

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Compliance data such as year-end census information

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Employer, plan and vendor information for setup in Retirement Manager

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Inbound SPARK file

Plan sponsors are responsible for reviewing reports (such as data inconsistency reports and aggregation reports)

provided by VALIC and notifying VALIC of any discrepancies or corrections on a timely basis.

Plan sponsors are responsible for reviewing and filing appropriate forms such as Form 5500.

Backup of Programs and Data Files (Control Objective 16)

The participant data processing department has the responsibility to recover critical application software and data.

The participant has the responsibility to validate procedures and policies are in place to support the recovery and

operation of critical applications.

III. Description of the VALIC Defined Contribution Plan Administration System