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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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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

9.4 The daily transfer agent

transactions are reconciled for

all cashmovement by fund,

shares outstanding, and NAV by

individual fund product. Evidence

of review and approval is provided

on the Trade Summary by Source

document which encompasses all

supporting schedules.

Inspected the Transfer Agent

Summary by Source reconciliations for

a sample of days to determine whether

the reconciliation was prepared and

independently approved on a daily

basis. For any discrepancies identified

in reconciliations, inspected evidence

to determine whether they were

researched and resolved.

No exceptions noted.

9.5 The completion of daily

reconciliation for annuities is

recorded on the Unit Value

Report Review Checklist and on

the Unit Value Reasonableness

Test. The completion of the daily

reconciliation for group mutual

funds is recorded on the Share

Value Pricing Review Checklist.

An independent review of the

reconciliation is required and

evidenced in the reconciliation

of the Checklist.

Inspected a sample of the Unit Value

Report Review Checklist and the

Share Value Pricing Review Checklist

to determine whether the daily

reconciliations were performed for

annuities and mutual funds.

Inspected the Unit Value Report Review

Checklist and the Share Value Pricing

Review Checklist to determine whether

they were reviewed and approved by a

separate member of the VPA team.

No exceptions noted.

No exceptions noted.

9.6 Dividend payment schedules are

monitored to confirm recording of

distributions by fund managers.

Inspected a sample of the Dividend

Verification Reports to determine

whether it was prepared to ensure the

dividend rates from UVT agree to the

dividend rates from VMS.

No exceptions noted.

9.7 The review and approval of

the Remote Wire Upload

encompasses cash movement to

all non-VALIC fund companies

and validates the purchase

or redemption of the trading

activity for the day as well as

the total shares outstanding at

each non-VALIC fund company.

This review and approval

process includes verification

that each fund was notified via

electronic communication of the

day’s activity and total shares

outstanding.

Inspected a sample of the VALIC

Remote Wire Upload to confirm

evidence of review and approval was

maintained from authorized signers.

Inspected evidence to verify each

fund was notified via electronic

communication of the day’s activity

and total shares outstanding.

No exceptions noted.

No exceptions noted.

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VALIC

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

effectiveness and results of tests