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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

11.7 A Retirement Manager

Disbursement Eligibility module

is available for plan sponsors

using aggregated disbursement

information for 403(b) and

457(b) plans in Retirement

Manager. Retirement Manager

calculates loan, hardship

withdrawal or unforeseen

emergency, in-service exchange,

severance of employment, and

age-based distribution eligibility

based on 403(b), 457(b) or

specific plan restrictions. The

resulting certificate is used by the

plan participant to request final

approval from the designated

vendor based on individual

contract restrictions.

Observed a disbursement to determine

when Disbursement Eligibility Module

was activated, whether Retirement

Manager calculated loan, hardship

withdrawal or unforeseen emergency,

in-service exchange, severance

of employment, and age-based

distribution eligibility.

No exceptions noted.

11.8 In cases where a 403(b) or

457(b) plan has multiple

campus locations governed

by the same plan document,

Retirement Manager can

perform compliance services

for disbursement requests and

provide disbursement reporting

based on plan data under all

campus locations.

Observed a plan with multiple campus

locations governed by the same plan

document to determine whether

Retirement Manager performed

compliance services for disbursement

requests and provided disbursement

reporting based on plan data.

No exceptions noted.

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

effectiveness and results of tests