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 61
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
5.4 Automated controls within the
application prevent
invalid and incomplete Asset
Allocation transactions from
being set up. Only available funds
are displayed and allocations
must equal 100%.
Observed Business Analyst log into
to determine whether
transactions are prevented from
processing when the maximum allowed
active vehicle was exceeded.
Observed Business Analyst log into
to determine whether
transactions are prevented from
processing when Future Contribution
Allocation Amounts did not equal 100%.
No exceptions noted.
No exceptions noted.
5.5 A transaction confirmation is
sent to the participant by a third-
party vendor upon completion
of Asset Allocations or TOV
transactions. VALIC performs a
daily reconciliation of transaction
confirmation counts sent from
VALIC to the third-party vendor
and transaction confirmation
counts received from the third-
party vendor.
Inspected a sample of Asset
Allocations and TOV changes to
determine whether VALIC Participant
Reporting performed a daily
reconciliation between confirmation
counts VALIC sent to the third-party
vendor and the counts VALIC received
from them, and any discrepancies
were investigated and resolved.
Reperformed a sample of daily
reconciliations to determine whether
confirmation counts VALIC sent to
the third-party vendor agreed to the
confirmation counts VALIC received
from them.
Inspected a sample of third-party
invoices to determine whether VALIC
utilizes the third-party vendor to send
TOV and Asset Allocation change
confirmations.
No exceptions noted.
No exceptions noted.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests