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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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Record Keeping - Benefit Payments
Control Objective 6
- Controls provide reasonable assurance that benefit payments 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
6.1 Participant and plan
documentation is reviewed
for completeness of required
documents, accuracy against
participant information in the
record keeping systems, and that
proper signatures were obtained
prior to completion of benefit
payments processing.
Test performed by the FCU team:
Surrenders and Withdrawals:
Inspected a sample of surrenders and
withdrawals to determine whether a
quality review was performed by a CDP.
Death Claims:
Inspected a sample of original
certificates of death or affidavit for lost
certificate if the original is unavailable
to determine whether a quality review
was performed by a CSP.
Systematic Withdrawals:
Inspected a sample of Systematic
Withdrawal or Minimum Distribution
Election Forms to determine whether a
quality review was performed by a CSP.
No exceptions noted.
No exceptions noted.
No exceptions noted.
6.2 Upon completion of the
participant's request, an
independent quality review is
performed to ensure accuracy
and completeness.
Test performed by the FCU team:
Surrenders and Withdrawals:
Inspected a sample of surrenders and
withdrawals to determine whether a
quality review was performed by an
individual other than the processor.
Death Claims:
Inspected a sample of original
certificates of death or affidavit for lost
certificate if the original is unavailable
to determine whether a quality review
was performed by an individual other
than the processor.
Systematic Withdrawals:
Inspected a sample of systematic
withdrawal or Minimum Distribution
Election Form to determine whether
a quality review was performed by an
individual other than the processor
prior to payment.
No exceptions noted.
No exceptions noted.
No exceptions noted.
6.3 Benefit payments failing to
process in the record keeping
system are recorded on an error
report. This report is reviewed
daily and appropriate corrections
are made.
Inspected a sample of AWD
cumulative error reports to determine
whether they were generated and
reviewed 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.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests