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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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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

10.5 A roll-forward is performed on

the total fixed account values on a

monthly basis.

Inspected a sample of the monthly

roll-forwards to determine whether

the roll-forward for total fixed account

values was performed.

No exceptions noted.

10.6 The Interest Crediting Committee

meets monthly and reviews and

approves the interest crediting

rates.

Test performed by the FCU team:

Inspected a sample of monthly

reviews of the interest crediting rates

to determine whether the Interest

Crediting Committee met and

approved the rates.

No exceptions noted.

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

effectiveness and results of tests