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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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Participant Reporting

Control Objective 8

- Controls provide reasonable assurance that transaction confirmations, participant account

statements, and plan reports are accurate, complete, and are delivered to participants without intervention.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

8.1 The Group Manager database is

used to track plan reports due

dates to verify that the reports

are generated.

Inspected a sample of group plan reports

to determine whether management

reviewed the database to track all

standard report due dates and monitor

whether reports were generated.

No exceptions noted.

8.2 Plan reports are reconciled and

corrected, if necessary prior to

making them available to the plan

sponsors.

Inspected a sample of daily error

reports to determine whether the

reports were reviewed and errors, if

any, were reconciled and corrected on

a daily basis.

No exceptions noted.

8.3 VALIC uses a third-party

vendor to prepare and mail

quarterly account statements

to participants. A reconciliation

is performed of the number of

Social Security numbers sent

to the vendor with the number

of Social Security numbers

processed. Additionally, the

vendor sends VALIC electronic

copies of the quarterly

account statements which are

maintained in COLD.

Test performed by the FCU team:

Inspected a sample of quarterly

account statements processed to

determine whether VALIC Client

Reporting performed a reconciliation

between Social Security number

counts VALIC sent to the vendor and

the Social Security number counts

VALIC received from the vendor

and investigated and resolved any

discrepancies.

Inspected a sample of quarterly

account statements to determine

whether copies sent by the vendor

were maintained in COLD.

No exceptions noted.

No exceptions noted.

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

effectiveness and results of tests