787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
February 5, 2021
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | VALIC Company I (File No. 002-83631) Registration Statement on Form N-14 |
Ladies and Gentlemen:
On behalf of VALIC Company I (the “Registrant”), and pursuant to Rule 488 under the Securities Act of 1933, as amended, we hereby transmit for filing with the Securities and Exchange Commission the Registrant’s Registration Statement on Form N-14 (the “Registration Statement”) relating to the proposed acquisition by the applicable series of the Registrant set out in the following table under the heading “Acquiring Funds,” of all of the assets and liabilities of the applicable series of VALIC Company II (“VC II”) set out in the following table under the heading “Target Funds,” in exchange for the shares of the corresponding Acquiring Fund.
Target Funds (each a series of VC II) | Acquiring Funds (each a series of the Registrant) |
Small Cap Value Fund | Small Cap Value Fund |
Capital Appreciation Fund | Capital Appreciation Fund |
Aggressive Growth Lifestyle Fund | Aggressive Growth Lifestyle Fund |
Moderate Growth Lifestyle Fund | Moderate Growth Lifestyle Fund |
Conservative Growth Lifestyle Fund | Conservative Growth Lifestyle Fund |
International Opportunities Fund | International Opportunities Fund |
High Yield Bond Fund | High Yield Bond Fund |
Mid Cap Value Fund | Mid Cap Value Fund |
U.S. Socially Responsible Fund | U.S. Socially Responsible Fund |
New York Washington Houston Palo Alto San Francisco Chicago Paris London Frankfurt Brussels Milan Rome
February 5, 2021
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Pursuant to Rule 488, the Registration Statement designates an effective date of March 8, 2021. Should members of the Staff have any questions regarding the enclosed materials, they should call the undersigned at (212) 728-8037.
Sincerely,
/s/ Stacey P. Ruiz |
Stacey P. Ruiz
Enclosures
cc: | Kathleen Fuentes, Esq,, SunAmerica Asset Management, LLC Christopher J. Tafone, Esq,, SunAmerica Asset Management, LLC Elliot J. Gluck, Esq., SunAmerica Asset Management, LLC |