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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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Asset Valuation

Control Objective 10

- Controls provide reasonable assurance that transactions and participant account balances

are valued based on market prices obtained from authorized pricing sources.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

10.1 VPA personnel validate asset

valuation by reconciling the

calculated change in reported

NAV to the actual reported

change in NAV and the

percentage change in unit value

from the net asset values of the

underlying investment vehicles to

help prevent or detect errors in

the unit value calculations.

Inspected a sample of the Unit

Value Change to NAV Change

Reasonableness Check Report

to determine whether they were

completed and reviewed by separate

members of the VPA group.

For any variances identified in

reconciliations, inspected evidence

to determine whether they were

researched and resolved.

No exceptions noted.

No exceptions noted.

10.2 VPA personnel validate asset

valuation for group mutual

funds by comparing the share

values received from the NSCC

to share values received by the

vendor VMS.

Inspected a sample of the Final NAV

Comparison Report to determine

whether the comparison was

completed and reviewed by VPA.

For any variances identified in

reconciliations, inspected evidence

to determine whether they were

researched and resolved.

No exceptions noted.

No exceptions noted.

10.3 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.

The reconciliations are prepared

and reviewed by separate

individuals.

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.

10.4 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.

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

effectiveness and results of tests