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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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Retirement Manager

Control Objective 11

- Controls provide reasonable assurance that employer, plan and vendor information setup

in Retirement Manager is authorized and processed accurately, completely and in accordance with instructions

received from the plan sponsors, vendors and participants.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

11.1 A quality review is completed

to validate that Retirement

Manager is set up according to

the employer plan and vendor

information received.

Inspected a sample of Employer, Plan,

and Vendor information setups in

Retirement Manager to determine

whether the quality review checklist

was completed and Implementation

Coordinator quality review

was performed.

No exceptions noted.

11.2 A Retirement Manager

Contribution Limit Enforcement

module is available for selected

plan sponsors with IRC 403(b),

401(k), 401(a)/403(a),

414(h) and 457(b) plan types.

Retirement Manager proactively

reduces or stops deferral

amounts for employees to

prevent excess contributions

calculated by the system.

Observed a contribution to determine

that for a plan where the Contribution

Limit Enforcement module was

activated, whether Retirement Manager

proactively reduced or stopped the

contribution when the participant's

contribution limit was reached.

No exceptions noted.

11.3 A Retirement Manager Hardship

Withdrawal Enforcement module

is available for selected plan

sponsors with an IRC 403(b)

plan type. Retirement Manager

suspends elective contributions

for a period of six months or more

if designated by the plan.

Observed a contribution to determine

when Hardship Withdrawal

Enforcement Module was activated,

and whether Retirement Manager

suspended the elective contribution

and indicated a suspension period.

Observed Retirement Manager

to determine whether Retirement

Manager blocked ongoing contribution

and the remaining payroll dates were

made unavailable.

No exceptions noted.

No exceptions noted.

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

effectiveness and results of tests