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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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VALIC

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Record Keeping - Check and EFT Payments

Control Objective 7

- Controls provide reasonable assurance that the processing of check and EFT payments are

properly authorized and processed accurately.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

7.1 The check writer printers are

located in a secured room in

Accounting. Only appropriate

individuals have access to this

room via the security card reader

system.

Observed whether the check writer

printer was secured in a room with

card reader restricted access and

whether only cards programmed with

access to the room allowed entry.

Inspected the card reader access

report from Security to determine

whether physical access to the check

writer room was appropriate.

No exceptions noted.

No exceptions noted.

7.2 Before non-automated on-

demand policy check requests

are entered, Accounting submits

requests to Compliance for OFAC

review and reviews the approved

requests and verifies approval

limits against the On-Demand

Disbursement Authorizations

table to confirm requests

are within the appropriate

authorization levels.

Test performed by the FCU team:

Inspected a sample of non-automated

on-demand check requests to

determine whether the appropriate

approvals were obtained based on the

business policy.

No exceptions noted.

7.3 Accounting compares the

payee, address, amount,

document number and issuing

company on the non-automated

on-demand check to the TAPS

check request to ensure data

was entered correctly.

Test performed by the FCU team:

Inspected a sample of non-automated

on-demand checks to determine

whether evidence of an Accounting’s

review of the manual check to the

TAPS request exists to ensure data

was entered correctly.

No exceptions noted.

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

effectiveness and results of tests