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 58
Record Keeping - Loans
Control Objective 4 - Controls provide reasonable assurance that loans are properly authorized and processed
accurately, completely, and in accordance with instructions received from plan sponsors or participants and in
compliance with the plan document.
VALIC Control Activities Tests of Operating Effectiveness Results of Tests
4.1 and AGILEnet
validate participant eligibility to
request a loan and the amount
allowed.
Observed a loan request transaction
for a participant with zero balance
to determine whether the system
prevented a loan request as the
participant was not eligible.
Observed a loan request transaction
to determine whether the system
prevented a loan request when the
loan request amount was greater than
the maximum eligible amount.
Observed a loan request transaction
to determine whether the system
prevented a loan request when the
participant has a defaulted loan.
No exceptions noted.
No exceptions noted.
No exceptions noted.
4.2 For ERISA loan requests, an
acknowleged ERISA Loan
Form Disclosure Statement
is required with all applicable
loan documentation prior to
processing loan requests.
Inspected a sample of ERISA loan
request documentation to determine
whether a completed and signed ERISA
Loan Form Disclosure Statement or
BEP Setup Confirmation was included
with applicable loan documentation
prior to processing loan requests.
No exceptions noted.
4.3 Documentation and approvals
included with the loan request
are validated by comparing
information on the loan
request documentation to data
contained on the record keeping
system. An independent
quality review is performed for
completeness and accuracy in
setting up the loan. If the loan
information is correct, the loan
is approved for set up. If an
error is identified, request is
returned with instructions for
correction.
Test performed by the FCU team:
Inspected a sample of loan setups
to determine whether the quality
reviewer checked the participant
information (name, Social Security
number, account number and
amount) to ensure the information
was accurately added to the record
keeping system.
Inspected a sample of loan setups to
determine whether a quality review
was performed and errors, if any,
were corrected.
No exceptions noted.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests