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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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Investment Processing
Control Objective 9
- Controls provide reasonable assurance that investment income (or loss) is accurately and
timely allocated and recorded to participant accounts.
VALIC Control Activities
Tests of Operating Effectiveness
Results of Tests
9.1 VPAmanagement reviews and
authorizes the daily investment
transactions sent to each
respective fundmanager.
Reviewed and approved as
noted on the reconciliation
report of the Checklist.
Inspected a sample of the Variable
Share and Dollar Reconciliations
for annuities and mutual funds for a
sample of days to determine whether
the reconciliation was prepared and
independently reviewed on a daily
basis. For any variances identified in
reconciliations, inspected evidence
to determine whether they were
researched and resolved.
No exceptions noted.
9.2 A reconciliation occurs for
annuity and group mutual funds
investment holdings recorded in
the trading applications (UVT)
to the record keeping system
on a daily basis. Evidence of
review and approval of the
reconciliations are noted on
the reconciliation report of
the Checklist.
Inspected a sample of the Shares to
Units Reconciliation and Shares to
Shares Reconciliations to determine
whether reconciliations were prepared
and reviewed by VPA. For any variances
identified in reconciliations, inspected
evidence to determine whether they
were researched and resolved.
No exceptions noted.
9.3 Cash movement is reconciled
on a daily basis by comparing
the expected cash movement
from the trade tickets to the
actual cash movement reported
by Treasury (OLE Reports).
Evidence of review and approval
is provided on the reconciliation
report of the Checklist.
Inspected a sample of the expected
cash vs. actual cash movement to
determine whether the reconciliation
was prepared and reviewed by
VPA. For any variances identified in
reconciliations, inspected evidence
to determine whether they were
researched and resolved.
Reperformed the reconciliations by
comparing the cash movement reports
to bank statements and identifying
variances.
No exceptions noted.
No exceptions noted.
IV. VALIC control objectives and controls, and PricewaterhouseCoopers LLP's tests of operating
effectiveness and results of tests