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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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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

3.12 An error report is generated from

the record keeping system daily

for any payment that does not

apply to a loan. The exceptions

are researched, corrected and

processed upon resolution.

Inspected a sample of error reports

and corresponding AWD Work

History to determine whether errors

were reviewed and resolved by the

Loan CSP.

No exceptions noted.

3.13 Bank-rejected checks or

individual ACHs for loan

payments are reversed out

of the record keeping system

by the Loan CSPs from each

participant’s affected account.

Inspected a sample of returned checks

and rejected ACHs to determine

whether they were reversed from the

participant’s account. For NSF voided

checks, inspected evidence to determine

whether letter was sent to participant

requesting replacement funds and

replacement funds were received and

applied to appropriate accounts.

No exceptions noted.

3.14 Management reviews a report

daily to ensure Common Remitter

remittances are processed.

Inspected Daily System Reconciliation

policy and procedure to determine

whether it is maintained.

Inspected a sample of reconciliations

of unprocessed remittances to

determine whether they were

completed by an Analyst and reviewed

by a Team Manager. If discrepancies

were identified, inspected the

reconciliation for evidence that the

team members identified, researched

and resolved the discrepancy.

No exceptions noted.

No exceptions noted.

3.15 An index file of the scanned

documents is routed to AWD

for processing. The job that

routes the image file to AWD is

monitored for processing.

Observed evidence of the Windows

service used to transfer the index file

of the scanned documents to AWD.

Observed the configuration to

monitor for errors to determine

whether notifications are sent to the

appropriate individuals in the event of

a process failure.

No exceptions noted.

No exceptions noted.

3.16 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.

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

effectiveness and results of tests