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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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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

4.4 ​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.

4.5 Participants are authenticated

within the

VALIC.com

application

using a unique User ID and

passwords that are in accordance

with AIG Policy.

Observed a Business Analyst log in

to

VALIC.com

participant account to

determine whether a unique User ID

and a password are required.

Observed password parameter

requirements when resetting a

password to determine whether they

are in accordance with AIG Policy.

No exceptions noted.

No exceptions noted.

4.6 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.

4.7 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.

Click

VALIC

.com 59

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

effectiveness and results of tests