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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

11.9 Retirement Manager restricts

the data at the plan sponsors,

vendors and participant level.

Plan sponsors can only access

data belonging to their plans

and cannot see any other plan

information. Vendors can only

view data for participants that

have enrolled with their company.

Participants can only view their

own personal data.

Observed a Business Analyst log into

Retirement Manager to determine

whether Retirement Manager

restricts information based on user's

information so plan sponsors can

only access data belonging to their

plans, vendors can only view data for

participants that have enrolled with

their company, and participants can

only view their personal data.

No exceptions noted.

11.10 A monthly review is completed

of all outbound SPARK files

generated to external third

parties to ensure that the plan

information is provided.

For a sample of monthly reviews,

inspected the outbound SPARK files

to determine whether they were

successfully transmitted and reviewed

by management. If files were not

successfully transmitted, inspected

evidence to determine whether issue

was researched and resolved.

No exceptions noted.

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

effectiveness and results of tests