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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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Record Keeping - Remittances
Control Objective 3
- Controls provide reasonable assurance that remittances are credited to participant accounts
accurately, completely, and in accordance with instructions received from plan sponsors or participants.
VALIC Control Activities
Tests of Operating Effectiveness
Results of Tests
3.1 Remittances and instructions are
received daily and monitored to
ensure they are invested effective
the business day of receipt if
received in good order prior to
the close of the New York Stock
Exchange.
Observed V-Systemonline screens
to determine whether deposits and
bill instructions were matched once
processed in the nightly cycle.
Observed a remittance payment received
in good order to determine whether it was
processed on the same day.
No exceptions noted.
No exceptions noted.
3.2 Remittances are set up
systematically on the record
keeping system daily by an MICR
transmission received from JP
Morgan Chase Bank, based on the
cash receipts from each lockbox.
Observed a systematic deposit header
setup to determine whether the
deposit header matched to the cash
receipts from the lockbox and was
automatically set up within V-System.
No exceptions noted.
3.3 Remittances are set up manually
by Accounting Operations based
on cash receipts received in The
Bank of New York Mellon (BoNY)
bank accounts on a daily basis.
Test performed by the FCU team:
Inspected a sample of deposit
headers and compared the BoNY
information to the V-System header
data to determine whether the
deposits were established accurately
in the V-System.
No exceptions noted.
3.4 Inventories of outstanding
remittances are monitored and
signed off by management weekly
using the Outstanding Remittance
Tracking, outstanding deposits,
and outstanding money in header
record keeping system reports.
Test performed by the FCU team:
Inspected a sample of the 124 and 141
reports to determine whether each
was reviewed on a weekly basis by
management. For any discrepancies
noted, inspected whether issues were
investigated and resolved.
No exceptions noted.
3.5 The record keeping system
prevents remittances that do not
balance with their instructions
from processing in the record
keeping system.
Observed V-System to determine
whether it prevented remittances
deposits that did not balance with their
instructions from processing.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests