Valic Retirement Services TA-1/A Registration as a transfer agent (amended)

Form TA-1 Filer Information	UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A	OMB APPROVAL
FORM TA-1/A		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	2929 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

corporation or partner information Related to item 8 Record: 2

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

corporation or partner information Related to item 8 Record: 3

8(a)(i). Full Name	Kara R. Boling
8(a)(ii). Relationship Start Date	06/28/2016
8(a)(iii). Title or Status	Executive Vice President & COO
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 4

8(a)(i). Full Name	Barbara Rayll
8(a)(ii). Relationship Start Date	11/30/2023
8(a)(iii). Title or Status	Vice President
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

Entity information Related to item 9(a) Record: 1

9(a)(i). Exact name of each person or entity:

The Variable Annuity Life Insurance Company, AGC Life Insurance Company, AIG Life Holdings, Inc., Corebridge Financial, Inc., and American Intl Group.

9(a)(ii). Description of the Agreement or other basis:

American International Group, Inc.'s ("AIG") share ownership of Corebridge Financial, Inc. ("Corebridge Financial"), the publicly-traded parent company of VALIC Retirement Services Company, and the rights granted to AIG by Corebridge Financial as part of a separation agreement between AIG and Corebridge Financial, provide AIG with control over Corebridge Financial's corporate and business activities.

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	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: 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: 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: 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; 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.

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	12.04 - 149432J
10(d)(1)(iii). Date of Action	12/05/2017
10(d)(1)(iv). The Court or body taking the Action and its location	Tennessee Department of Insurance
10(d)(1)(v). Description of the Action	On 04/06/2016, VALIC Financial Advisors, Inc. (VFA) filed an insurance agency application in the state of Tennessee. Due to an administrative error, the application failed to include certain VFA Regulatory Disclosures. Upon recognizing the error, VFA amended its insurance agency application on 9/30/2017. On 1/31/2018, the State of Tennessee Insurance Division issued a civil penalty against VFA in the amount of $500.00 for failing to include the regulatory disclosures in the initial application.
10(d)(1)(vi). The disposition of the proceeding	VFA signed the agreed final order and paid the fine totaling $500.00.

Entity information Related to item 10(d)(1) Record: 7

10(d)(1)(i). The individuals named in the Action	VALIC Financial Advisors, Inc. (VFA)
10(d)(1)(ii). Title of Action	State of Ohio Department of Insurance
10(d)(1)(iii). Date of Action	05/23/2017
10(d)(1)(iv). The Court or body taking the Action and its location	State of Ohio Department of Insurance
10(d)(1)(v). Description of the Action	On 04/06/2016, VALIC Financial Advisors, Inc. (VFA) filed an insurance agency application on the behalf in the state of Ohio. Due to an administrative error, the application failed to include certain VFA Regulatory Disclosures. Upon recognizing the error, VFA amended its insurance agency application on September 30. On May 23, the Ohio Department of Insurance issued an administrative fine against VFA in the amount of $500.00 for inadvertently omitting regulatory disclosure in the initial application. The administrative fine invoice was received by VFA on June 26, 2017, at which time it was promptly paid.
10(d)(1)(vi). The disposition of the proceeding	VFA paid the $500 fine issued by the state.

Entity information Related to item 10(d)(1) Record: 8

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: AGN266722
10(d)(1)(iii). Date of Action	01/23/2017
10(d)(1)(iv). The Court or body taking the Action and its location	State of Maine Bureau of Insurance
10(d)(1)(v). Description of the Action	On 04/06/2016, VALIC Financial Advisors, Inc. (VFA) filed an insurance agency application on the behalf in the state of Maine. Due to an administrative error, the application failed to include certain VFA Regulatory Disclosures. Upon recognizing the error, VFA amended its insurance agency application on September 30. On January 23, the State of Maine Bureau of Insurance issued an administrative fine against VFA in the amount of $50.00 for failing to include the regulatory disclosures in the initial application. The correspondence was not received by VFA until March 22, at which time payment of the fee was arranged.
10(d)(1)(vi). The disposition of the proceeding	VFA paid the $50 fine issued by the state on 4/7/2017.

Entity information Related to item 10(d)(1) Record: 9

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: 68901
10(d)(1)(iii). Date of Action	11/29/2016
10(d)(1)(iv). The Court or body taking the Action and its location	Virginia Bureau of Insurance
10(d)(1)(v). Description of the Action	On 04/06/2016, VALIC Financial Advisors, Inc. (VFA) filed an insurance agency application in the state of Virginia. Due to an administrative error, the application omitted certain FINRA Regulatory actions. VFA amended its application on September 30. On November 29, the State issued an administrative fine against VFA in the amount of $500.00 for omitting the 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.

Entity information Related to item 10(d)(1) Record: 10

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: 1000474400
10(d)(1)(iii). Date of Action	12/13/2016
10(d)(1)(iv). The Court or body taking the Action and its location	North Carolina Department of Insurance
10(d)(1)(v). Description of the Action	On 04/06/2016, VALIC Financial Advisors, Inc. (VFA) filed an insurance agency application in the state of North Carolina. Due to an administrative error, the application omitted certain FINRA Regulatory events. VFA amended its application on September 30. On December 16, the State issued an administrative fine against VFA in the amount of $250.00 for omitting the 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 $250 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	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

Entity information Related to item 10(d)(2) Record: 2

10(d)(2)(i). The individuals named in the Action	VALIC Financial Advisors, Inc.
10(d)(2)(ii). Title of Action	Docket/Case Number: 20-0168
10(d)(2)(iii). Date of Action	02/25/2020
10(d)(2)(iv). The Court or body taking the Action and its location	State of Washington Office of the Insurance Commissioner
10(d)(2)(v). Description of the Action	Due to an administrative error, VFA's Washington business entity license listed an invalid email address. The state used that contact information to send correspondence which ultimately was not received by VFA. The state issued an administrative fine against VFA in the amount of $250 for failure to have at least one licensed affiliate and failure to respond to those inquiries.
10(d)(2)(vi). The disposition of the proceeding	VFA signed the agreed final order and paid the fine totaling $250.00.

Entity information Related to item 10(d)(2) Record: 3

10(d)(2)(i). The individuals named in the Action	VALIC Financial Advisors, Inc.
10(d)(2)(ii). Title of Action	Delaware Department of Insurance
10(d)(2)(iii). Date of Action	05/06/2021
10(d)(2)(iv). The Court or body taking the Action and its location	Delaware Department of Insurance
10(d)(2)(v). Description of the Action	On June 23, 2021, the Delaware Department of Insurance signed a consent order fining VFA $500 for failing to timely report VFA's January 8, 2021 Letter of Acceptance, Waiver, and Consent with FINRA.
10(d)(2)(vi). The disposition of the proceeding	VFA signed the agreed final order and paid the fine totaling $500.00.

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	Louisiana Department of Insurance
10(d)(2)(iii). Date of Action	06/14/2021
10(d)(2)(iv). The Court or body taking the Action and its location	Louisiana Department of Insurance
10(d)(2)(v). Description of the Action	On July 14, 2021, the Louisiana Department of Insurance signed a consent order fining VFA $500 for failing to timely report VFA's January 8, 2021 Letter of Acceptance, Waiver, and Consent with FINRA.
10(d)(2)(vi). The disposition of the proceeding	VFA signed the agreed final order and paid the fine totaling $500.00.

Entity information Related to item 10(d)(2) Record: 5

10(d)(2)(i). The individuals named in the Action	The Variable Annuity Life Insurance Company
10(d)(2)(ii). Title of Action	Docket/Case Number: 24-012-I
10(d)(2)(iii). Date of Action	08/05/2024
10(d)(2)(iv). The Court or body taking the Action and its location	State of Vermont Department of Financial Regulation
10(d)(2)(v). Description of the Action	On September 5, 2024, The Variable Annuity Life Insurance Company paid a $16,000 voluntary forfeiture to the State of Vermont Department of Financial Regulation to resolve the Department's finding of a violation of V.S.A. Section 2435(b)(3) for failing to notify the Department of a data breach for a Vermont consumer within 14 days of the date the Company discovered the breach or the date the Company provides notice to consumers, whichever is earlier.
10(d)(2)(vi). The disposition of the proceeding	Consent order. Administrative Penalty of $16,000.

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

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	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: 2

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: 3

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: 4

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.

Entity information Related to item 10(d)(4) Record: 5

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; No. MIA-2021-09-023
10(d)(4)(iii). Date of Action	09/30/2021
10(d)(4)(iv). The Court or body taking the Action and its location	Maryland Insurance Administration
10(d)(4)(v). Description of the Action	On September 21, 2021, American General Life Insurance Company paid a $32,250.00 administrative fine to the Maryland Insurance Administration to resolve alleged violations arising out of the State's routine market conduct examination of the Company's individual life insurance business, covering the time period of June 1, 2018 through January 31, 2020.
10(d)(4)(vi). The disposition of the proceeding	Order. Administrative Fine in the amount of $32,250.

Entity information Related to item 10(d)(4) Record: 6

10(d)(4)(i). The individuals named in the Action	The United States Life Insurance Company in the City of New York
10(d)(4)(ii). Title of Action	In the Matter of The United States Life Insurance Company, No. 2020-0232-S
10(d)(4)(iii). Date of Action	12/12/2023
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 December 12, 2023, The United States Life Insurance Company in the City of New York ("USL") paid a $5,146,245 civil penalty to the NYSDFS to resolve alleged violations arising out of the state's routine market conduct examination.
10(d)(4)(vi). The disposition of the proceeding	Consent order. Civil Penalty in the amount of $5,146,245.

Entity information Related to item 10(d)(4) Record: 7

10(d)(4)(i). The individuals named in the Action	American General Life Insurance Company
10(d)(4)(ii). Title of Action	In Re: American General Life Insurance Company, Docket No.: Ins. No. 24-012-EP
10(d)(4)(iii). Date of Action	04/03/2024
10(d)(4)(iv). The Court or body taking the Action and its location	New Hampshire Insurance Department
10(d)(4)(v). Description of the Action	On March 30, 2024, American General Life Insurance Company paid an administrative penalty of $2,500 to the New Hampshire Insurance Department to resolve alleged violations that the Company violated NH RSA 400-A:16, II by failing to respond within 10 working days to the NHID's January 10, 2024 request and by failing to respond within 10 working days to the NHID's January 30, 2024 request.
10(d)(4)(vi). The disposition of the proceeding	Consent Order. Administrative Fine in the amount of $2,500.

Entity information Related to item 10(d)(4) Record: 8

10(d)(4)(i). The individuals named in the Action	The Variable Annuity Life Insurance Company
10(d)(4)(ii). Title of Action	Docket No. 24-012-I
10(d)(4)(iii). Date of Action	08/05/2024
10(d)(4)(iv). The Court or body taking the Action and its location	State of Vermont Department of Financial Regulation
10(d)(4)(v). Description of the Action	On September 5, 2024, The Variable Annuity Life Insurance Company paid a $16,000 voluntary forfeiture to the State of Vermont Department of Financial Regulation to resolve the Department's finding of a violation of V.S.A. Section 2435(b)(3) for failing to notify the Department of a data breach for a Vermont consumer within 14 days of the date the Company discovered the breach or the date the Company provides notice to consumers, whichever is earlier.
10(d)(4)(vi). The disposition of the proceeding	Consent Order. Administrative Penalty of $16,000.

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

10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant?  Yes   No

10(e). Has any self-regulatory organization or commodities exchange ever:

10(e)(1). found the applicant or a control affiliate to have made a false statement or omission?  Yes   No

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	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.

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	Docket/Case Number: E062005009701
10(e)(2)(iii). Date of Action	10/31/2006
10(e)(2)(iv). The Court or body taking the Action and its location	FINRA
10(e)(2)(v). Description of the Action	NASD Rules 2110, 2830(k), 3010, 3070 - Respondent member violated the directed brokerage provisions by accepting directed brokerage commissions in exchange for providing a mutual fund company with preferred access to its sales force. The findings stated that the firm failed to report, or to timely report, disclosure events pursuant to NASD Rule 3070. The findings also stated that the firm failed to establish, maintain, and enforce a system and procedures reasonably designed to achieve compliance with Federal Securities Laws and NASD Rule 3070 Reporting Requirements.
10(e)(2)(vi). The disposition of the proceeding	Without admitting or denying the findings, VALIC Financial Advisors, Inc. consented to the described sanctions and to the entry of findings, therefore, the firm was censured and fined $250,000.

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

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

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:	Todd McGrath
11(b). Telephone Number:	713-831-8000
11(c). Title of Signing Officer:	Chief Operating Officer
11(d). Date Signed (Month/Day/Year):	10/03/2024