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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 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

14.4 Finance performs a daily

balancing of administrative

system general ledger entries

in SAP. Any unbalanced general

ledger entries are corrected.

Inspected a sample of SAP daily

and monthly balancing reports to

determine whether reports were

reviewed for out of balance entries,

and any out of balance entries

identified were resolved.

No exceptions noted.

14.5 Batch processing job abends

are identified, investigated and

resolved in a timely manner.

Inspected a sample of job abends to

assess whether an incident ticket was

created as a result of the abend and

whether the incident was researched

and resolved in timely manner (i.e. in

accordance with the Severity Levels).

Inspected the Autosys and CA-7 job

scheduling tools to determine whether

job failures resulted in the automated

creation of a ServiceNow incident

ticket.

No exceptions noted.

No exceptions noted.

14.6 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