| Form TA-1 Filer Information | UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A | OMB APPROVAL |
| OMB Number: 3235-0084 Estimated average burden hours per response: 1.5 |
TA-1/A : Filer Information
Form Version X0405 |
| 1(a). Filer CIK: | 0001202048 |
| 1(b). Filer CCC: | ******** |
| 1(c). Is this a LIVE or TEST submission? |  Live  Test |
| 1(d). Would you like a Return Copy? |  Yes |
Submission Contact Information
The registrant may provide a single e-mail address for contact purposes.| 1(f)(i). Contact Name: | |
| 1(f)(ii). Contact Phone Number: | |
| 1(f)(iii). Contact E-Mail Address: |
Notification Information
The registrant may provide additional e-mail addresses for those persons the filer would like to receive notification e-mails regarding the filing.| 1(g). Notification E-mail Address: |
TA-1/A : Registrant Information
| 2. Appropriate regulatory agency (check one): | Securities and Exchange Commission Federal Deposit Insurance Corporation Comptroller of the Currency |
| 3(a). Full Name of Registrant: | VALIC RETIREMENT SERVICES CO |
| 3(a)(i). Previous name, if being amended: | AIG RETIREMENT SERVICES CO |
| 3(b). Financial Industry Number (FINS) number: | 502575 |
3(c). Address of principal office where transfer agent activities are, or will be, performed:
| 3(c)(i). Address 1 | 2919 Allen Parkway |
| 3(c)(ii). Address 2 | |
| 3(c)(iii). City | Houston |
| 3(c)(iv). State or Country | TEXAS |
| 3(c)(v). Postal Code | 77019 |
| 3(d). Is Mailing address different from response to Question 3c? If "yes" provide address(es): | Yes No |
| 3(e). Telephone Number (Include Area Code) | 713-831-3150 |
| 4. Does Registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Questions 3(c) above? If "Yes" provide address (es): | Yes No |
| 5. Does registrant act, or will it act, as a transfer agent solely for its own securities, and/or securities of an affiliate(s)? | Yes No |
| 6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions? | Yes No |
| 7. Has registrant been engaged, or will it be engaged as a service company by a named transfer agent to perform transfer agent functions? | Yes No |
TA-1/A : Independent, Non-Issuer Registrant Information
Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select "Not Applicable".
| 8. Is registrant a: | Corporation |
Section for Initial Registration and for Amendments Reporting Additional Persons.
corporation or partner information Related to item 8 Record: 1| 8(a)(i). Full Name | The Variable Annuity Life Insurance Company (VALIC) |
| 8(a)(ii). Relationship Start Date | 11/18/1996 |
| 8(a)(iii). Title or Status | Owner |
| 8(a)(iv). Ownership Code | E |
| 8(a)(v). Control Person | Yes |
| 8(a)(vi). Relationship End Date |
| 8(a)(i). Full Name | Glenn R. Harris |
| 8(a)(ii). Relationship Start Date | 01/15/2015 |
| 8(a)(iii). Title or Status | Director |
| 8(a)(iv). Ownership Code | NA |
| 8(a)(v). Control Person | Yes |
| 8(a)(vi). Relationship End Date | 04/30/2021 |
| 8(a)(i). Full Name | Eric S. Levy |
| 8(a)(ii). Relationship Start Date | 06/29/2016 |
| 8(a)(iii). Title or Status | Director and Senior Vice President |
| 8(a)(iv). Ownership Code | NA |
| 8(a)(v). Control Person | Yes |
| 8(a)(vi). Relationship End Date | 06/17/2021 |
| 8(a)(i). Full Name | Freda Lee |
| 8(a)(ii). Relationship Start Date | 06/17/2021 |
| 8(a)(iii). Title or Status | Executive Vice President |
| 8(a)(iv). Ownership Code | NA |
| 8(a)(v). Control Person | Yes |
| 8(a)(vi). Relationship End Date |
| 8(a)(i). Full Name | Todd McGrath |
| 8(a)(ii). Relationship Start Date | 06/17/2021 |
| 8(a)(iii). Title or Status | President |
| 8(a)(iv). Ownership Code | NA |
| 8(a)(v). Control Person | Yes |
| 8(a)(vi). Relationship End Date |
| 8(a)(i). Full Name | Cheryl Tibbits |
| 8(a)(ii). Relationship Start Date | 06/17/2021 |
| 8(a)(iii). Title or Status | Executive Vice President & CFO |
| 8(a)(iv). Ownership Code | NA |
| 8(a)(v). Control Person |  Yes |
| 8(a)(vi). Relationship End Date |
9. Does any person or entity not named in the answer to Question 8:
| 9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant, or;…. | Yes No |
| 9(a)(i). Exact name of each person or entity: | The Variable Annuity Life Insurance Company, AGC Life Insurance Company, AIG Life Holdings, Inc., SAFG Retirement Services, and American Intl Group. |
| 9(a)(ii). Description of the Agreement or other basis: | The VALIC Retirement Services Company is 100 owned by The Variable Annuity Life Insurance Company. The Variable Annuity Life Insurance Company is 100 percent owned by AGC Life Insurance Company, which is 100 percent owned by AIG Life Holdings, Inc., which is 100 percent owned by SAFG Retirement Services, Inc. (DE), which is 100 percent by owned American International Group, Inc. (AIG). |
| 9(b). wholly or partially finance the business of the applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others?….. | Yes No |
TA-1/A : 10. Applicant and Control Affiliate Disciplinary History
The following definitions apply for purposes of answering this Question 10
| Control Affiliate | - An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority. |
| Investment or investment related | - Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association). |
| Involved | - Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act. |
10(a). In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contendere ("no contest") to:
| 10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting, or extortion? | Yes No |
| 10(a)(2). any other felony? | Yes No |
| 10(b). Has any court in the past ten years: | |
| 10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity? | Yes No |
| 10(b)(2). found that the applicant or control affiliate was involved in a violation of investment-related statutes or regulations? | Yes No |
| 10 (c). Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever: | |
| 10(c)(1). found the applicant or control affiliate to have made a false statement or omission? | Yes No |
Entity information Related to item 10(c)(1) Record: 1
| 10(c)(1)(i). The individuals named in the Action | American International Group, Inc. |
| 10(c)(1)(ii). Title of Action | Injunction |
| 10(c)(1)(iii). Date of Action | 02/06/2006 |
| 10(c)(1)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(1)(v). Description of the Action | THE SEC COMPLAINT ALLEGED THAT FROM 2000 UNTIL 2005, AIG MATERIALLY FALSIFIED ITS FINANCIAL STATEMENTS IN ORDER TO STRENGTHEN THE APPEARANCE OF ITS FINANCIAL RESULTS TO ANALYSTS AND INVESTORS. IN SO DOING, THE SEC ALLEGED THAT AIG HAD VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933 AND SECTIONS 10(B), 13(A), 13(B)(2) AND 13(B)(5) AND RULES 10B-5, 12B-20, 13A-1, 13A-13 AND 13B2-1 OF THE EXCHANGE ACT OF 1934. |
| 10(c)(1)(vi). The disposition of the proceeding | Settled 2/17/2006 |
Entity information Related to item 10(c)(1) Record: 2
| 10(c)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(c)(1)(ii). Title of Action | In the Matter of VALIC Financial Advisors, Inc. SEC File No. 3-19894 |
| 10(c)(1)(iii). Date of Action | 07/28/2020 |
| 10(c)(1)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(1)(v). Description of the Action | On July 28, 2020, the United States Securities and Exchange Commission ("SEC") issued an administrative order against VALIC Financial Advisors, Inc. ("VFA" or the "Firm") finding that the Firm failed to disclose to certain Florida teachers that the Firm's parent company, VALIC, provided cash and other financial benefits to a for-profit company owned by Florida K-12 teachers' unions in exchange for referring teachers to products and services offered by VALIC and the Firm, in violation of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-3 thereunder. The SEC also found that VFA did not adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder, in violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. VFA neither admitted nor denied the SEC's findings. |
| 10(c)(1)(vi). The disposition of the proceeding | Solely for the purpose of settling the proceeding, VFA consented to a cease-and-desist order, a censure, and to pay a civil monetary penalty of $20 million, which was paid on July 31, 2020. VFA agreed to comply with certain undertakings as well. |
Entity information Related to item 10(c)(1) Record: 3
| 10(c)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(c)(1)(ii). Title of Action | In the Matter of VALIC Financial Advisors, Inc. SEC File No. 3-19895 |
| 10(c)(1)(iii). Date of Action | 07/28/2020 |
| 10(c)(1)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(1)(v). Description of the Action | On July 28, 2020, the United States Securities and Exchange Commission ("SEC") issued an administrative order against VALIC Financial Advisors, Inc. ("VFA") regarding certain VFA mutual fund and mutual fund share class selection practices. Specifically, the SEC found that the Firm had not appropriately disclosed certain conflicts of interest due to its receipt of revenue sharing, avoidance of transaction fees, and receipt of 12b-1 fees, in violation of Section 206(2) of the Advisers Act. The SEC also found that VFA did not adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices, in violation of Section 206(4) of the Advisers Act of 1940 and Rule 206(4)-7 thereunder. VFA neither admitted nor denied the SEC's findings. |
| 10(c)(1)(vi). The disposition of the proceeding | Solely for the purpose of settling the proceeding, VFA consented to a cease-and-desist order, a censure, and disgorgement of $13,232,681, prejudgment interest of $2,211,072, and a $4.5 million civil penalty, paid on 8/7/2020, and certain undertakings. |
| 10(c)(2). found the applicant or control affiliate to have been involved in a violation of its regulation or statutes? | Yes No |
Entity information Related to item 10(c)(2) Record: 1
| 10(c)(2)(i). The individuals named in the Action | American International Group, Inc. |
| 10(c)(2)(ii). Title of Action | Docket SDNY - Case No. 06 CIV 1000 |
| 10(c)(2)(iii). Date of Action | 02/09/2006 |
| 10(c)(2)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(2)(v). Description of the Action | The SEC Complaint alleged that from 2000 until 2005, AIG materially falsified its financial statements in order to strengthen the appearance of its financial results to analysts and investors. In so doing, the SEC Alleged that AIG had violated Section 17(A) of The Securities Act of 1933 and Sections 10(B), 13(A), 13(B)(2) and 13(B)(5) and Rules 10B-5, 12B-20, 13A-1, 13A-13 and 13B2-1 of the Exchange Act. |
| 10(c)(2)(vi). The disposition of the proceeding | Settled 2/17/2006 |
Entity information Related to item 10(c)(2) Record: 2
| 10(c)(2)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(c)(2)(ii). Title of Action | In the Matter of VALIC Financial Advisors, Inc. SEC File No. 3-19894 |
| 10(c)(2)(iii). Date of Action | 07/28/2020 |
| 10(c)(2)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(2)(v). Description of the Action | On July 28, 2020, the United Stated Securities and Exchange Commission ("SEC") issued an administrative order against VALIC Financial Advisors, Inc. ("VFA" or the "Firm") finding that the Firm failed to disclose to certain Florida teachers that the Firm's parent company, VALIC, provided cash and other financial benefits to a for-profit company owned by Florida K-12 teachers' unions in exchange for referring teachers to products and services offered by VALIC and the Firm, in violation of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-3 thereunder. The SEC also found that VFA did not adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder, in violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. VFA neither admitted nor denied the SEC's findings. |
| 10(c)(2)(vi). The disposition of the proceeding | Solely for the purpose of settling the proceeding, VFA consented to a cease-and-desist order, a censure, and to pay a civil monetary penalty of $20 million, which was paid on July 30, 2020. VFA agreed to comply with certain undertakings as well. |
Entity information Related to item 10(c)(2) Record: 3
| 10(c)(2)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(c)(2)(ii). Title of Action | In the Matter of VALIC Financial Advisors, Inc. SEC File No. 3-19895 |
| 10(c)(2)(iii). Date of Action | 07/28/2020 |
| 10(c)(2)(iv). The Court or body taking the Action and its location | Securities and Exchange Commission |
| 10(c)(2)(v). Description of the Action | On July 28, 2020, the United States Securities and Exchange Commission ("SEC") issued an administrative order against VALIC Financial Advisors, Inc.("VFA") regarding certain VFA mutual fund and mutual fund share class selection practices. Specifically, the SEC found that the Firm had not appropriately disclosed certain conflicts of interest due to its receipt of revenue sharing, avoidance of transaction fees, and receipt of 12b-1 fees, in violation of Section 206(2) of the Advisers Act. The SEC also found that VFA did not adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices, in violation of Section 206(4) of the Advisers Act of 1940 and Rule 206(4)-7 thereunder. VFA neither admitted nor denied the SEC's findings. |
| 10(c)(2)(vi). The disposition of the proceeding | Solely for the purpose of settling the proceeding, VFA consented to a cease-and-desist order, a censure, and disgorgement of $13,232,681, prejudgment interest of $2,211,072, and a $4.5 million civil penalty, paid on 8/7/2020, and certain undertakings. |
| 10(c)(3). found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted? | Yes No |
| 10(c)(4). entered an order denying, suspending or revoking the applicant’s or control affiliate’s registration or otherwise disciplined it by restricting its activities? | Yes No |
| 10(d). Has any other Federal regulatory agency or any state regulatory agency : | |
| 10(d)(1). ever found the applicant or control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical? | Yes No |
Entity information Related to item 10(d)(1) Record: 1
| 10(d)(1)(i). The individuals named in the Action | The VARIABLE ANNUITY LIFE INSURANCE COMPANY (VALIC) |
| 10(d)(1)(ii). Title of Action | Docket/Case Number: 08-1728-9 |
| 10(d)(1)(iii). Date of Action | 08/06/2015 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | West Virginia Securities Commission |
| 10(d)(1)(v). Description of the Action | The State alleged in twenty-four separate summary orders 1) VALIC acted as an investment adviser without proper registration, 2) advertisement violation, 3) VALIC and its agent defrauded investors by misleading them, misrepresenting material facts, and implying the were representatives of the school board or the State, 4) statements/omissions were misleading and constituted a scheme to defraud WV residents, and 5) failure of VALIC's agent to disclose to his client that was employed and controlled by VALIC. |
| 10(d)(1)(vi). The disposition of the proceeding | Vacated 5/3/2019. |
Entity information Related to item 10(d)(1) Record: 2
| 10(d)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(d)(1)(ii). Title of Action | Docket/Case Number: 16-0572-DEN |
| 10(d)(1)(iii). Date of Action | 06/14/2016 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | State of Oklahoma Insurance Department |
| 10(d)(1)(v). Description of the Action | Due to an administrative error, VFA omitted certain FINRA regulatory actions on its insurance agency application. |
| 10(d)(1)(vi). The disposition of the proceeding | VFA agreed to settlement and paid $300 administrative fine. |
Entity information Related to item 10(d)(1) Record: 3
| 10(d)(1)(i). The individuals named in the Action | Sean Placido Rodriguez |
| 10(d)(1)(ii). Title of Action | File No. LCB 1159-A |
| 10(d)(1)(iii). Date of Action | 11/22/2013 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | California Department of Insurance |
| 10(d)(1)(v). Description of the Action | Failed to report December 22, 2012, settlement with FINRA |
| 10(d)(1)(vi). The disposition of the proceeding | California Insurance License revoked/restricted license issued. |
Entity information Related to item 10(d)(1) Record: 4
| 10(d)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(d)(1)(ii). Title of Action | Docket/Case Number: 16-0572-DEN |
| 10(d)(1)(iii). Date of Action | 06/24/2016 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | State of Oklahoma Insurance Department |
| 10(d)(1)(v). Description of the Action | VFA filed an administrative agency application on behalf of VALIC Financial Advisors, Inc., in the the State of Oklahoma. Due to an administrative error, the application omitted certain FINRA Regulatory Actions. VFS amended its application. The State issued an administrative fine against VFA for $300 for omitting the regulatory event in its application. |
| 10(d)(1)(vi). The disposition of the proceeding | VFA agreed to settlement and paid the $300 administrative fee. |
Entity information Related to item 10(d)(1) Record: 5
| 10(d)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(d)(1)(ii). Title of Action | Docket/Case Number: 100130340 |
| 10(d)(1)(iii). Date of Action | 10/07/2016 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | Alaska Division of Insurance |
| 10(d)(1)(v). Description of the Action | Alaska issued an administrative fine against VFA in the amount of $100 for failing to timely report the fine issued by the State of Oklahoma. |
| 10(d)(1)(vi). The disposition of the proceeding | VFA settled the matter and paid the fine. |
Entity information Related to item 10(d)(1) Record: 6
| 10(d)(1)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(d)(1)(ii). Title of Action | Docket/Case Number; 11/7/2016 |
| 10(d)(1)(iii). Date of Action | 11/07/2016 |
| 10(d)(1)(iv). The Court or body taking the Action and its location | Louisiana Department of Insurance |
| 10(d)(1)(v). Description of the Action | Louisiana issued an administrative fine against VFA for $500 for omitting prior regulatory events in the initial application and failing to timely report the fine issued by the State of Oklahoma. |
| 10(d)(1)(vi). The disposition of the proceeding | VFA settled the matter and paid the $500 fine. |
| 10(d)(2). ever found the applicant or control affiliate to have been involved in a violation of investment-related regulations or statutes? | Yes No |
Entity information Related to item 10(d)(2) Record: 1
| 10(d)(2)(i). The individuals named in the Action | Zachary Ranstead Pittinger (VALIC Financial Advisors, Inc.) |
| 10(d)(2)(ii). Title of Action | Docket/Case Number: IC10-CAF-01 |
| 10(d)(2)(iii). Date of Action | 01/22/2010 |
| 10(d)(2)(iv). The Court or body taking the Action and its location | Texas State Securities Board |
| 10(d)(2)(v). Description of the Action | Alleged that investment advisory services were provided without being registerered as an IAR. |
| 10(d)(2)(vi). The disposition of the proceeding | Reprimand, $4,000 Fine |
Entity information Related to item 10(d)(2) Record: 2
| 10(d)(2)(i). The individuals named in the Action | William Hilton Burke (VALIC Financial Advisors, Inc.) |
| 10(d)(2)(ii). Title of Action | Docket/Case Number: 0096-SR-7/10 |
| 10(d)(2)(iii). Date of Action | 08/09/2010 |
| 10(d)(2)(iv). The Court or body taking the Action and its location | Florida Office of Financial Regulation |
| 10(d)(2)(v). Description of the Action | Allegedly conducted investment advisory business without the benefit of lawful registration. |
| 10(d)(2)(vi). The disposition of the proceeding | Ceast and desist, $2,500 Fine. |
Entity information Related to item 10(d)(2) Record: 3
| 10(d)(2)(i). The individuals named in the Action | Sean Placido Rodriguez (VALIC Financial Advisors, Inc.) |
| 10(d)(2)(ii). Title of Action | Case Number 2010023804801 |
| 10(d)(2)(iii). Date of Action | 12/18/2012 |
| 10(d)(2)(iv). The Court or body taking the Action and its location | FINRA |
| 10(d)(2)(v). Description of the Action | Allegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations. |
| 10(d)(2)(vi). The disposition of the proceeding | AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000 |
Entity information Related to item 10(d)(2) Record: 4
| 10(d)(2)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. |
| 10(d)(2)(ii). Title of Action | SEU-2018-001 |
| 10(d)(2)(iii). Date of Action | 05/30/2019 |
| 10(d)(2)(iv). The Court or body taking the Action and its location | Hawaii Department of Commerce and Consumer Affairs |
| 10(d)(2)(v). Description of the Action | Hawaii alleged that the firm failed to supervise a registered representative who had submitted a transactions without proper customer authorization. |
| 10(d)(2)(vi). The disposition of the proceeding | Monetary/Fine $10,000. Cease and Desist/Injunction |
| 10(d)(3). ever found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business Denied, suspended, revoked or restricted? | Yes No |
Entity information Related to item 10(d)(3) Record: 1
| 10(d)(3)(i). The individuals named in the Action | Sean Placido Rodriguez (VALIC Financial Advisors, Inc.) |
| 10(d)(3)(ii). Title of Action | Case Number 2010023804801 |
| 10(d)(3)(iii). Date of Action | 12/18/2012 |
| 10(d)(3)(iv). The Court or body taking the Action and its location | FINRA |
| 10(d)(3)(v). Description of the Action | Allegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations. |
| 10(d)(3)(vi). The disposition of the proceeding | AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000 |
| 10(d)(4). in the past ten years entered an order against the applicant or control affiliate in connection with investment-related activity? | Yes No |
Entity information Related to item 10(d)(4) Record: 1
| 10(d)(4)(i). The individuals named in the Action | Sean Placido Rodriguez (VALIC Financial Advisors, Inc.) |
| 10(d)(4)(ii). Title of Action | Case Number 2010023804801 |
| 10(d)(4)(iii). Date of Action | 12/18/2012 |
| 10(d)(4)(iv). The Court or body taking the Action and its location | FINRA |
| 10(d)(4)(v). Description of the Action | Allegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations. |
| 10(d)(4)(vi). The disposition of the proceeding | AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000 |
Entity information Related to item 10(d)(4) Record: 2
| 10(d)(4)(i). The individuals named in the Action | American General Life Insurance Company |
| 10(d)(4)(ii). Title of Action | Docket/Case Number: 10-076-S |
| 10(d)(4)(iii). Date of Action | 09/20/2010 |
| 10(d)(4)(iv). The Court or body taking the Action and its location | Vermont Dept of Banking, Insurance, Securities and Healthcare Administration ("B |
| 10(d)(4)(v). Description of the Action | SunAmerica Annuity and Life Assurance Company ("SALAC") merged into American General Life Insurance Company ("AGLIC") in December 2012. AGLIC is a related person of Varagon Capital Partners, L.P. BISHCA alleged that SALAC violated the Vermont Uniform Securities Act by (1) using a prospectus that was ambiguous in describing its automatic asset re-balance program feature applicable to certain variable annuities, and (2) not re-balancing certain sub-accounts within the annuities to return to allocations given in the account owners' last trade instructions. |
| 10(d)(4)(vi). The disposition of the proceeding | Stipulation and Consent. Sanction ordered in the amount of $100,000. |
Entity information Related to item 10(d)(4) Record: 3
| 10(d)(4)(i). The individuals named in the Action | American General Life Insurance Company American International Group, Inc. |
| 10(d)(4)(ii). Title of Action | In the Matter of, American General Life Insurance Company American International |
| 10(d)(4)(iii). Date of Action | 01/28/2021 |
| 10(d)(4)(iv). The Court or body taking the Action and its location | New York State Department of Financial Services |
| 10(d)(4)(v). Description of the Action | American International Group, Inc. ("AIG") and AGL entered into a consent order with New York State Department of Financial Services finding that AGL had conducted an insurance business in New York without a New York license in connection with its Pension Risk Transfer ("PRT") business, in violation of insurance law section 1102(A). |
| 10(d)(4)(vi). The disposition of the proceeding | Order made findings only against AGL. AGL paid a $12,000,000 civil penalty on 02/05/2021. Pursuant to the order, AGL will also take agreed upon actions with respect to NY-based participants in legacy and future PRT transactions. |
Entity information Related to item 10(d)(4) Record: 4
| 10(d)(4)(i). The individuals named in the Action | American General Life Insurance Company |
| 10(d)(4)(ii). Title of Action | In the Matter of American General Life Insurance Company, Docket No. 4516 |
| 10(d)(4)(iii). Date of Action | 08/12/2021 |
| 10(d)(4)(iv). The Court or body taking the Action and its location | State of Delaware Department of Insurance |
| 10(d)(4)(v). Description of the Action | On August 12, 2021, American General Life Insurance Company paid a $106,000 administrative fine to the Delaware Department of Insurance to resolve alleged violations arising out of the state's routine market conduct examination of the company's individual life and individual annuity business. |
| 10(d)(4)(vi). The disposition of the proceeding | Stipulation and Consent. Administrative Penalty in the amount of $106,000. |
Entity information Related to item 10(d)(4) Record: 5
| 10(d)(4)(i). The individuals named in the Action | The Variable Annuity Life Insurance Company |
| 10(d)(4)(ii). Title of Action | In the Matter of The Variable Annuity Life Insurance Company, No. 2021-0089-S |
| 10(d)(4)(iii). Date of Action | 09/21/2021 |
| 10(d)(4)(iv). The Court or body taking the Action and its location | New York State Department of Financial Services |
| 10(d)(4)(v). Description of the Action | On September 17, 2021, VALIC paid a $230,820 administrative fine to the NYSDFS to resolve alleged violations arising out of the state's routine market conduct examination of the company's group and individual annuity business. |
| 10(d)(4)(vi). The disposition of the proceeding | Consent Order. Administrative Penalty in the amount of $230,820. |
| 10(d)(5). ever denied, suspended, or revoked applicant’s or control affiliate’s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities? | Yes No |
Entity information Related to item 10(d)(5) Record: 1
| 10(d)(5)(i). The individuals named in the Action | Sean Placido Rodriguez (VALIC Financial Advisors, Inc.) |
| 10(d)(5)(ii). Title of Action | Case Number 2010023804801 |
| 10(d)(5)(iii). Date of Action | 12/18/2012 |
| 10(d)(5)(iv). The Court or body taking the Action and its location | FINRA |
| 10(d)(5)(v). Description of the Action | Allegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations. |
| 10(d)(5)(vi). The disposition of the proceeding | AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000 |
| 10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant? | Yes No |
Entity information Related to item 10(d)(6) Record: 1
| 10(d)(6)(i). The individuals named in the Action | Robert Jacob Bourgeois (Varagon Capital Partners, LP) |
| 10(d)(6)(ii). Title of Action | Docket/Case Number: 1205-10164 |
| 10(d)(6)(iii). Date of Action | 09/12/2012 |
| 10(d)(6)(iv). The Court or body taking the Action and its location | Texas State Board of Public Accountancy |
| 10(d)(6)(v). Description of the Action | License may be reinstated upon completion on continuing education requirements and payment of penalty fee. |
| 10(d)(6)(vi). The disposition of the proceeding | Suspension/Administrative revocation: CPA License |
| 10(e)(1). found the applicant or a control affiliate to have made a false statement or omission? | Yes No |
Entity information Related to item 10(e)(1) Record: 1
| 10(e)(1)(i). The individuals named in the Action | Renee Lynn Coil (VALIC Financial Advisors, Inc) |
| 10(e)(1)(ii). Title of Action | Docket/Case Number: 2008014756401 |
| 10(e)(1)(iii). Date of Action | 07/30/2010 |
| 10(e)(1)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(1)(v). Description of the Action | Alleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges. |
| 10(e)(1)(vi). The disposition of the proceeding | One-month suspension |
| 10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules? | Yes No |
Entity information Related to item 10(e)(2) Record: 1
| 10(e)(2)(i). The individuals named in the Action | AIG Capital Services, Inc. |
| 10(e)(2)(ii). Title of Action | Docket/Case Number: C11000014 |
| 10(e)(2)(iii). Date of Action | 07/07/2000 |
| 10(e)(2)(iv). The Court or body taking the Action and its location | National Association of Securities Dealers, Inc. |
| 10(e)(2)(v). Description of the Action | The NASD alleged AIG Capital Services, Inc. ("ACS") failed to establish, maintain, and enforce written supervisory procedures reasonably designed to achieve compliance with applicable rules of NASD, to ensure (I) the timely filing and processing of registration applications; (II) the timely filing and processing of notices reporting terminations of employment; and (III) that its registered representatives fulfilled the requirements of the regulatory element of the continuing education program. |
| 10(e)(2)(vi). The disposition of the proceeding | AWC/Sanctions Ordered: Censure, Monetary Fine $75,000.00. |
Entity information Related to item 10(e)(2) Record: 2
| 10(e)(2)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(e)(2)(ii). Title of Action | Docket/Case Number: 2014042360001 |
| 10(e)(2)(iii). Date of Action | 11/28/2016 |
| 10(e)(2)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(2)(v). Description of the Action | Alleged violations of NASD Rule 3010)(A)(B) and FINRA Rules 2010, 2330( C), (D), and E. |
| 10(e)(2)(vi). The disposition of the proceeding | AWC: Censure, Monetary Fine $1,750,000 |
Entity information Related to item 10(e)(2) Record: 3
| 10(e)(2)(i). The individuals named in the Action | Renee Lynn Coil (VALIC Financial Advisors, Inc) |
| 10(e)(2)(ii). Title of Action | Docket/Case Number: 2008014756401 |
| 10(e)(2)(iii). Date of Action | 07/30/2010 |
| 10(e)(2)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(2)(v). Description of the Action | Alleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges. |
| 10(e)(2)(vi). The disposition of the proceeding | One-month suspension |
Entity information Related to item 10(e)(2) Record: 4
| 10(e)(2)(i). The individuals named in the Action | VALIC Financial Advisors, Inc. (VFA) |
| 10(e)(2)(ii). Title of Action | Matter No. 2018060548501 |
| 10(e)(2)(iii). Date of Action | 01/08/2021 |
| 10(e)(2)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(2)(v). Description of the Action | On January 8, 2021, VALIC Financial Advisors, Inc. (VFA) completed a Letter of Acceptance, Waiver and Consent (AWC) with FINRA for the purpose of settling alleged FINRA rule violations that it failed to (i) establish a reasonably designed system and written supervisory procedures to monitor rates of variable annuity exchanges and implement corrective action in the case of inappropriate exchanges, violating FINRA Rules 2330(d), 3110, and 2010; (ii) reasonably supervise recommendations involving the investment of additional funds in an existing variable annuity, violating FINRA Rules 3110 and 2010, and (iii) timely report statistical and summary information for certain customer complaints during a specified period, violating FINRA Rules 4530(d) and 2010. VFA neither admitted nor denied FINRA's findings. Solely for the purpose of settling the proceeding, VFA consented to a censure and a fine of $350,000. |
| 10(e)(2)(vi). The disposition of the proceeding | VFA neither admitted nor denied FINRA's findings. Solely for the purpose of settling the proceeding, VFA consented to a censure and a fine of $350,000. |
| 10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business? | Yes No |
Entity information Related to item 10(e)(3) Record: 1
| 10(e)(3)(i). The individuals named in the Action | Renee Lynn Coil (VALIC Financial Advisors, Inc.) |
| 10(e)(3)(ii). Title of Action | Docket/Case Number: 2008014756401 |
| 10(e)(3)(iii). Date of Action | 07/30/2010 |
| 10(e)(3)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(3)(v). Description of the Action | Alleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges. |
| 10(e)(3)(vi). The disposition of the proceeding | One-month suspension |
| 10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities? | Yes No |
Entity information Related to item 10(e)(4) Record: 1
| 10(e)(4)(i). The individuals named in the Action | Renee Lynn Coil (VALIC Financial Advisors, Inc.) |
| 10(e)(4)(ii). Title of Action | Docket/Case Number: 2008014756401 |
| 10(e)(4)(iii). Date of Action | 07/30/2010 |
| 10(e)(4)(iv). The Court or body taking the Action and its location | FINRA |
| 10(e)(4)(v). Description of the Action | Alleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges. |
| 10(e)(4)(vi). The disposition of the proceeding | One-month suspension |
| 10(f). Has any foreign government, court, regulatory agency or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud? | Yes No |
| 10(g). Is the applicant or a control affiliate now the subject of a proceeding that could result in a yes answer for questions 10(a) – 10(f) ? | Yes No |
| 10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate? | Yes No |
| 10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it? | Yes No |
TA-1/A : Signature
ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a) SIGNATURE: The registrant submitting this form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.| 11(a). Signature of Official responsible for Form: | Kara R. Boling |
| 11(b). Telephone Number: | 713-831-6313 |
| 11(c). Title of Signing Officer: | Senior Vice President & Chief Operations Officer |
| 11(d). Date Signed (Month/Day/Year): | 10/12/2021 |