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 60
Record Keeping - TOV/Asset Allocation Changes
Control Objective 5 - Controls provide reasonable assurance that Transfer of Value and Asset Allocation changes
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
5.1 An independent quality review is
performed on manually entered
Transfer of Value (TOV) and
Asset Allocation changes.
Inspected the AWD workflow for a
sample of TOV and Asset Allocation
change (AAC) requests to determine
whether a quality review was performed.
Inspected evidence fromwithin
AGILEnet and AWD to determine that
a sample of TOV and Asset Allocation
changes were not processed unless
the quality review was completed
and the status changed in AWD from
"Processed" to "Passed."
No exceptions noted.
No exceptions noted.
5.2 Participants are authenticated
within the application
using a unique User ID and
passwords that are in accordance
with AIG Policy.
Observed a Business Analyst log in
to 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.
5.3 Automated controls within the
application prevent
invalid and incomplete TOV
transactions from being set up.
Edits prevent depleting more than
100% on “From” funds and only
available “To” funds display. The
sum of percentages allocated to
“To” funds must equal 100%.
Observed VALIC Online to determine
whether an error message is displayed
and transactions are prevented from
processing when the “Transfer From”
amount is greater than the available
transfer amount for each fund chosen.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests