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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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Program Execution Controls

Control Objective 14

- Controls provide reasonable assurance that processing is monitored and deviations are

identified and resolved.

VALIC Control Activities

Tests of Operating Effectiveness

Results of Tests

14.1 In order to request a temporary

override to a production job or job

schedule, the VALIC application

programmer must fill out an

authorized request form in the

ticketing system tool and obtain

appropriate approval from VALIC

Management.

Mainframe

Inspected a sample of job overrides

to mainframe production jobs to

determine whether each override was

appropriately approved by a VALIC

Manager.

No exceptions noted.

Distributed Systems

Inspected a sample of job overrides to

distributed systems production jobs to

determine whether each override was

appropriately approved by a VALIC

Manager.

No exceptions noted.

14.2 In the event of a mainframe

production abend or other

problem, the ticketing system

pages VALIC personnel until the

problem is resolved. Automated

escalation procedures are in

place to make sure there is

timely resolution of production

problems. Incidents are properly

reported, logged, and resolved.

Inspected a sample of V-System

production abends to determine

whether each issue was documented

in the ticketing system and incidents

were properly reported, logged, and

resolved.

No exceptions noted.

14.3 For distributed systems, there are

two jobs monitoring applications.

In the event of a production

problem, the job monitoring

software pages VALIC Information

Technology personnel until the

problem is resolved. Two daily

reports are sent to Application

Managers via emails that describe

the status of key production jobs.

The appropriate Application

Manager will follow the job to

resolution. Incidents are properly

reported, logged, and resolved.

Inspected a sample of the morning

and afternoon Self Service Back Office

Confirmation reports to determine

whether the status of production jobs

was sent to application managers

and problems were followed up for

resolution and incidents were properly

reported, logged, and resolved.

No exceptions noted.

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

effectiveness and results of tests