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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

.com 69

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

8.4 VALIC audits a sample of

quarterly account statements

prior to authorizing the release of

statements for mailing or online

viewing.

Inspected a sample of quarterly account

statements to determine whether

VALIC audited the statements prior to

authorizing the release of statements

for mailing or online viewing.

Inspected a sample of audits that

identified discrepancies in the pre-

production account statements to

determine whether the account

statements were corrected in a new

account statement.

No exceptions noted.

No exceptions noted.

8.5 A confirmation letter is sent to the

participant by a third-party vendor

upon completion of non-monetary

changes processed through

AGILEnet and

VALIC.com

. VALIC

performs a daily reconciliation of

confirmation counts sent from

VALIC to the third-party vendor

and confirmation counts received

from the third-party vendor.

Inspected a sample of non-monetary

beneficiary and data maintenance

changes to determine whether VALIC

or the third-party vendor sent a letter

to participants notifying them that a

change was made to their account.

Reperformed a sample of daily

reconciliations to determine whether

confirmation counts VALIC sent to

the third-party vendor agreed to the

confirmation counts VALIC received

from them.

No exceptions noted.

No exceptions noted.

8.6 A confirmation letter sent to the

participant upon completion

of non-monetary changes

processed through the record

keeping system and AWD.

Inspected a sample of non-monetary

beneficiary and data maintenance

changes processed manually to

determine whether confirmation

letters were sent to participants and

were stored in AWD.

No exceptions noted.

8.7 A transaction confirmation is

sent to the participant by a third-

party vendor upon completion

of Asset Allocations or TOV

transactions. VALIC performs a

daily reconciliation of transaction

confirmation counts sent from

VALIC to the third-party vendor

and transaction confirmation

counts received from the third-

party vendor.

Inspected a sample of Asset Allocations

and TOV changes to determine whether

VALIC Participant Reporting performed a

daily reconciliation between confirmation

counts VALIC sent to the third-party

vendor and the counts VALIC received

from them, and any discrepancies were

investigated and resolved.

Reperformed a sample of daily

reconciliations to determine whether

confirmation counts VALIC sent to

the third-party vendor agreed to the

confirmation counts VALIC received from

them.

Inspected a sample of third-party invoices

to determine whether VALIC utilizes

the third-party vendor to send TOV and

Asset Allocation change confirmations.

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