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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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Transaction processing controls

Contract/Plan Administration

Control Objective 1

- Controls provide reasonable assurance that plan parameters are set up in the system

accurately, completely and in accordance with the plan document for new plans.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

1.1 An independent quality review is

performed for new plan setups to

ensure the plan documentation

and data input agree.

Inspected a sample of Mutual Fund and

Annuity new plan setups for supporting

documentation to determine whether

the Mutual Fund/Annuity setup was

quality reviewed by an independent

team member.

No exceptions noted.

1.2 Applications for enrollments

are reviewed for in good order

processing prior to establishing

new participant accounts on the

record keeping systems.

Inspected a sample of new annuity and

mutual fund accounts to determine

whether data elements were received

and able to be processed prior to

establishing new participant accounts

in V- System.

No exceptions noted.

1.3 An independent quality review is

performed on a minimum of 10%

of enrollments to verify good order

and accuracy.

Inspected a sample and compared

annuity and mutual fund plans set up

to determine whether Account Set-up

team performs a quality review of 10%

or more of new accounts.

No exceptions noted.

1.4 An independent quality review

is performed for plan sponsor-

initiated variable mutual fund

adds, changes, and/or deletes

to ensure the plan amendment/

agreement or other plan sponsor

documentation and data

input agrees.

Inspected a sample of group

amendment requests initiated by

plan sponsors for variable mutual

fund additions, changes and/or

deletions to determine whether quality

review checklists were prepared and

approved. If any discrepancies were

noted in the quality review checklist,

determined whether the discrepancies

were followed up and resolved.

No exceptions noted.

1.5 New fund requests are reviewed

and set up in the record keeping

system and UVT reconciliation is

performed then and subsequently

reviewed by management.

Inspected a sample of new fund

setups to determine whether VPA

team performed a reconciliation of

information input to the fund request

from the Implementation Team and a

review was performed by management.

Reperformed a sample of VPA’s

reconciliation for the new fund setups

to determine whether fund was set up

accurately in V- System and UVT.

No exceptions noted.

No exceptions noted.

IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating

effectiveness and results of tests