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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 12A

- Controls provide reasonable assurance that changes to V-System are tested and approved

by VALICManagement.

Control Objective 12B

- Controls provide reasonable assurance that changes to distributed systems including

SAP are tested and approved by VALICManagement.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

12.8 (12B) All required approvals for

SAP changes (including business

and technology) are obtained

and documented prior to

migration of the change into the

production environment.

Inspected a sample of SAP changes

to determine whether changes were

approved prior to migration into the

production environment.

No exceptions noted.

12.9 Network infrastructure

changes performed by AIG IT

are appropriately authorized,

analyzed for impact, and include

back-out procedures prior to

loading into the production

environment to support effective

functioning of applications

at, and to protect data from

unauthorized changes.

Inspected a sample of infrastructure

changes to determine whether they

were appropriately authorized,

analyzed for impact, and included

back-out procedures prior to loading

into the production environment.

No exceptions noted.

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

effectiveness and results of tests