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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