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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 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

11.4 With regard to Contribution

Limits and HardshipWithdrawal

Enforcement modules, funds are

released to the vendor or returned

to the plan sponsor as instructed.

Observed a contribution to determine

whether the common remitter

service in Retirement Manager

completed a reactive process to

either 1) stop processing of the

individual excess contributions or

returning the contributions to the

employer plan sponsor after receiving

directions from the plan sponsor

or 2) suspend contributions due to

hardship withdrawal prior to releasing

funds to the vendor or returning the

contributions to the plan sponsor.

No exceptions noted.

11.5 Amonthly audit of inbound SPARK

files is performed to determine if

any of the expected plan data is not

received. If any of the data is not

received for active vendor plans

on RetirementManager, contact

ismadewith the vendor or plan

sponsor regarding the delay.

Inspected a sample of monthly audits

performed by VRSCO to determine

whether expected plan data was

received, by comparing the active

vendor plans on Retirement Manager

to the vendor plan SPARK data. For

any issues noted, inspected evidence

to determine whether they were

researched and resolved.

No exceptions noted.

11.6 Retirement Manager aggregates

disbursement information

from plan vendors due to

loan, hardship withdrawal or

unforeseen emergency, in-

service exchange, severance of

employment, and age-based

distributions and provides the

plan sponsor or vendors with

consolidated disbursement

reporting across vendors.

Observed a plan sponsor dashboard

within Retirement Manager to

determine whether the aggregated

disbursement data matches the SPARK

source file.

No exceptions noted.

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

effectiveness and results of tests