Business Continuity Statement The scope of VALIC Financial Advisors’ (VFA) business continuity planning today entails certain key VFA business operations and data center locations. Business continuity planning is the process which defines the procedures employed to ensure the timely and orderly resumption of a company’s business, through its ability to execute plans with minimal or no interruption to time-sensitive business operations. Specific plans have been developed and teams have been identified for each time-sensitive business operation. Each plan prioritizes the critical business functions and states a strategy for recovery within a specified timeframe. VFA’s ultimate parent company, the American International Group, Inc. (AIG) maintains the AIG Business Continuity Planning Department which has primary responsibility for the guidelines, methodologies, and the framework to support the strategies for recovery for all subsidiary companies including VFA. The AIG Business Continuity Planning infrastructure is responsible for developing and maintaining the plans. VFA Business Continuity Planning Objectives The objectives of the VFA Business Recovery Continuity Plan are to: Avoid or minimize deaths and injuries. Control and terminate incidents as quickly as possible. Prevent a minor incident from becoming a major disaster. Minimize commercial and reputation damage. Protect VFA assets and financial position. Minimize the risk of legal liabilities. Resume and recover any disrupted business function or operation rapidly and effectively. Ensure compliance with all applicable laws and regulations. Maintain the confidence and good relations with public safety and regulatory agencies customers, service providers, and other official parties. Satisfy the interests and concerns of VFA programs and other related business entities. VFA Business Continuity Guidelines The VFA Business Continuity Plans were developed in accordance with established methodology defined by American International Group, Inc. (AIG) following Business Continuity Planning best practices. Each business unit followed documented enterprise-wide guidelines for contingency planning and disaster recovery for various scenarios. These guidelines included the following: Risk Assessment – There are numerous risks to any business. From natural to man-made these risks can be, or may become, threats to VFA’s business. VFA threats with the greatest probability include storms or hurricanes, high water or flooding, fire, bomb threats, terrorist attacks, breach of security and general service interruption. A risk assessment was performed by VFA Facilities/Property Management for each VFA facility. Each business unit then assessed any additional risks that would pertain to that unit’s specific operation. Business Impact Analysis – Each VFA business unit is required to identify the time criticality of each business function, as well as the resources that the function needs to successfully recover. Additionally, each unit must review annually the time criticality of all business functions. Business Contingency Plan – VFA business units document and update annually a contingency plan to support the business unit’s needs. Contingency plans include event management procedures, employee communication strategies, alternate site requirements, and procedures for notification to clients, recovery management, and alternate site preparation checklists. Plan Testing – Once the recovery plan documentation is complete, it is tested regularly to ensure that recovery capability remains viable. At least one full-scale recovery simulation, or a series of logically organized, segmented exercises representing a full exercise, is conducted annually. In addition to full-scale recovery simulation tests, an annual tabletop/walkthrough exercise of the plan is conducted to gauge each participant’s understanding of individual roles and responsibilities. VFA Recovery Strategies Threats that materialize can cause varying degrees of outages that can be classified as short-term, intermediate-term, or long-term. Day-to-day emergencies are addressed at VFA through emergency response/escalation procedures that are used when needed. VFA Business Continuity Plans have been developed to address a variety of disaster categories. The categories are defined as follows: Short-Term: Workplace Damaged or Inaccessible Intermediate Term: Building Damaged or Campus Inaccessible Long-Term: Worst Case Scenario (Local or City-wide Evacuation) VFA Disaster Recovery AIG currently contracts with a third party vendor for recovery services. This third party vendor provides a recovery location for the Houston campus and many of the remote VFA branch offices. AIG also contracts for mainframe operations, which includes a recovery option for mainframe restoration. In the event of a disaster, VFA’s third party vendor will restore the mainframe at a SunGard remote facility. Once the mainframe is restored, business units will be able to access mainframe applications through a designated Disaster Recovery circuit. All business units currently accessing the mainframe through our local network will be able to access the mainframe during a disaster situation. When the AIG Houston main campus declares a disaster, the Technical Recovery Teams immediately send the required personnel and all back up tapes to the designated vendor recovery center to restore open systems. The Technical Recovery Team restores the infrastructure that allows for the recovery and restoration of critical business databases and applications to the most current recovery point as dictated by business requirements. Business users will be relocated to the end user recovery site or another appropriate location. Operations using Open Systems will continue at the hot site for 6 weeks or until the damaged facility is repaired or a suitable alternate facility is acquired. In the event VFA ceases operations, customers can call the customer service line at 800-572-1980. Contact Marian_Wendeline@AIGVALIC.com for questions regarding the business continuity plan. VFA and its clearing firm, National Financial Services, LLC, (NFS), have an agreement in which NFS may provide trade execution, clearing, and other related services for your brokerage account. NFS backs up VFA’s important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, VFA has been advised by NFS that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments in a timely manner. Your orders and requests for funds and securities could be delayed during this period. VALIC Financial Advisors, Inc. Member of FINRA, SIPC #40224