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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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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

7.4 Finance performs a daily

balancing of administrative

system general ledger entries

in SAP. Any unbalanced general

ledger entries are corrected.

Test performed by the FCU team:

Inspected a sample of SAP daily

and monthly balancing reports to

determine whether reports were

reviewed for out of balance entries,

and any out of balance entries

identified were resolved.

No exceptions noted.

7.5 Finance compares the record

keeping system balance totals to

the general ledger balances on a

monthly basis.

Inspected a sample of reconciliations

to determine whether monthly

reconciliations were performed by

Financial Reporting and any significant

variances were investigated and resolved.

Reperformed a sample of

reconciliations to determine whether

V-System balanced with SAP.

No exceptions noted.

No exceptions noted.

7.6 Automated manual checks have

appropriate approvals based on

appropriate business policies. The

requests are automatically sent

to SAP for processing subsequent

to the Transaction Account

Processing System (TAPS)

request from the requestor. The

request in the TAPS database

is noted as SAP Export with

respective batch number.

Test performed by the FCU team:

Inspected a sample of requests in the

TAPS database to determine whether

each request had a respective SAP

Export batch number.

Inspected a sample of automated on-

demand check requests to determine

whether checks had appropriate

approvals based on appropriate

business policies.

No exceptions noted.

No exceptions noted.

7.7 Non-automated on-demand

checks and wire transfer

requests are approved and

quality reviewed through TAPS

prior to issue.

Test performed by the FCU team:

Inspected a sample of manual check

requests to determine whether return

of premium was approved in the

Transaction Accounting Processing

System (TAPS) prior to payment and

in accordance with business policy.

Inspected a sample of the SAP

report of all return premium checks

over $500 to determine whether

management reviewed the report the

following business day in accordance

with business policy.

Inspected a sample of the report

monitoring returns of premiums

issued to OPT payees for amounts

over $200 to determine whether

management reviewed the following

business day in accordance with

business policy.

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