CSD-RT RFP Recordkeeping_Administration Services Response 3-

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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. Click VALIC.com 52
Record Keeping - Changes to Non-Monetary Data
Control Objective 2 - Controls provide reasonable assurance that modifications to non-monetary participant data
are properly authorized and are completely and accurately recorded.
VALIC Control Activities Tests of Operating Effectiveness Results of Tests
2.1 Non-monetary data changes are
reviewed to confirm they are in
“good order” prior to processing.
Inspected a sample of non-monetary
data changes to determine whether
each request was in “good order” prior
to processing.
No exceptions noted.
2.2 A confirmation letter is sent to the
participant by a third-party vendor
upon completion of non-monetary
changes processed through
AGILEnet and VALIC
performs a daily reconciliation
of confirmation counts sent from
VALIC to the third-party vendor
and confirmation counts received
from the third-party vendor.
Inspected a sample of non-monetary
beneficiary and data maintenance
changes to determine whether VALIC
or the third-party vendor sent a letter
to participants notifying them that a
change was made to their account.
Reperformed a sample of daily
reconciliations to determine whether
confirmation counts VALIC sent to
the third-party vendor agreed to the
confirmation counts VALIC received
from them.
No exceptions noted.
No exceptions noted.
2.3 A confirmation letter is manually
generated and sent by VALIC to
the participant upon completion of
non-monetary changes processed
through the record keeping system
and AWD.
Inspected a sample of non-monetary
beneficiary and data maintenance
changes processed manually to
determine whether confirmation
letters were sent to participants and
were stored in AWD.
No exceptions noted.
2.4 Complaints are monitored by
management and the Consumer
Affairs Department.
Inspected a sample of monthly
complaint reports to determine
whether customer complaints are
monitored by VALIC Management and
the Compliance Department.
No exceptions noted.
2.5 ​Incoming participant callers to the
Contact Center are verified before
providing any participant or account
specific information to the caller
or performing any transactions
for the caller.
Inspected a sample of incoming
participant calls to confirm that
prior to the release of confidential
participant or account information,
the VALIC team member verifies the
following: participant's name, Social
Security number or VALIC account
number, and date of birth.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests