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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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5.8 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.

5.9 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.

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VALIC

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

effectiveness and results of tests

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

5.6 If the participants’ account

records are not successfully

updated in the record keeping

system during the nightly cycle,

an error report is reviewed and

corrections made and the request

processed.

Inspected a sample of AWD

cumulative error reports to determine

whether they were generated and

reviewed by the CSP VALIC team

members on a daily basis. For items

not processed in the nightly cycle,

inspected evidence to determine that

they were investigated and resolved.

No exceptions noted.

5.7 ​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.