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Form ADV (full filing)

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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS

Primary Business Name: THE VARIABLE ANNUITY LIFE INSURANCE COMPANY CRD Number: 104561
Other-Than-Annual Amendment - All Sections Rev. 10/2021
7/9/2026 3:37:44 PM

WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal
prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information

Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the
information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.

A. Your full legal name (if you are a sole proprietor, your last, first, and middle names):
THE VARIABLE ANNUITY LIFE INSURANCE COMPANY

B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
THE VARIABLE ANNUITY LIFE INSURANCE COMPANY

List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.

(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box

If you check this box, complete a Schedule R for each relying adviser.

C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the
name change is of
your legal name or your primary business name:

D. (1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-8138
(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:
(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
No Information Filed

E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 104561

If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.

(2) If you have additional CRD Numbers, your additional CRD numbers:
No Information Filed

F. Principal Office and Place of Business
(1) Address (do not use a P.O. Box):
Number and Street 1: Number and Street 2:
2919 ALLEN PARKWAY 6TH FLOOR
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77019

If this address is a private residence, check this box:

List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If
you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to
which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your
most recently completed fiscal year.

(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:

Normal business hours at this location:
8:00AM - 5:00PM CST
(3) Telephone number at this location:
713-522-1111
(4) Facsimile number at this location, if any:
(5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of
the end of your most recently completed fiscal year?
0

G. Mailing address, if different from your principal office and place of business address:

Number and Street 1: Number and Street 2:
P.O. BOX 15648
City: State: Country: ZIP+4/Postal Code:
AMARILLO Texas United States 79105-5648

If this address is a private residence, check this box:

H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:

Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:

Yes No
I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and
LinkedIn)?

If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D.
If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing
addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly
available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the
addresses of employee accounts on publicly available social media platforms.

J. Chief Compliance Officer
(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact
information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.

Name: Other titles, if any:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:

Electronic mail (e-mail) address, if Chief Compliance Officer has one:

(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered
under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS
Employer Identification Number (if any):
Name:
IRS Employer Identification Number:

K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions
about this Form ADV, you may provide that information here.

Name: Titles:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:

Electronic mail (e-mail) address, if contact person has one:

Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law,
somewhere other than your principal office and place of business?

If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority?

Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial
regulatory authority. If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?

Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
If yes, what is the approximate amount of your assets:
$1 billion to less than $10 billion
$10 billion to less than $50 billion

$50 billion or more

For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using
the total assets shown on the balance sheet for your most recent fiscal year end.

P. Provide your Legal Entity Identifier if you have one:
549300K1BVLH9IO4S405

A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity
identifier.

SECTION 1.B. Other Business Names

No Information Filed

SECTION 1.F. Other Offices

No Information Filed

SECTION 1.I. Website Addresses

List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not
limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available
social media platform.

Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/@corebridgefinancial

Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/corebridge-for-financial-professionals/

Address of Website/Account on Publicly Available Social Media Platform: https://www.instagram.com/corebridgefinancial/

Address of Website/Account on Publicly Available Social Media Platform: https://www.facebook.com/CorebridgeFinancial

Address of Website/Account on Publicly Available Social Media Platform: https://www.corebridgefinancial.com/rs

Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/corebridgefinancial/

SECTION 1.L. Location of Books and Records

Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You
must complete a separate Schedule D, Section 1.L. for each location.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
15333 HEMPSTEAD RD
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77040-3011

If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
800-934-3454

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE KEPT BY THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND/OR THE INVESTMENT COMPANY ACT
OF 1940, AS AMENDED.

Name of entity where books and records are kept:
SUNAMERICA ASSET MANAGEMENT, LLC

Number and Street 1: Number and Street 2:
ONE WORLD TRADE CENTER SUITE J, 49TH FLOOR
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10007-0042

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-858-8850

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE KEPT IN COMPLIANCE WITH THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED AND/OR THE
INVESTMENT COMPANY ACT OF 1940, AS AMENDED.

Name of entity where books and records are kept:
SMARSH

Number and Street 1: Number and Street 2:
851 SW 6TH STREET STE 800
City: State: Country: ZIP+4/Postal Code:
PORTLAND Oregon United States 97204-1322

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
866-835-4164

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
ELECTRONIC COMMUNICATIONS

Name of entity where books and records are kept:
FIS GLOBAL

Number and Street 1: Number and Street 2:
347 RIVERSIDE AVE
City: State: Country: ZIP+4/Postal Code:
JACKSONVILLE Florida United States 32202-4909

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
904-438-6000

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
EMPLOYEE PERSONAL TRADING, CERTIFICATIONS AND OUTSIDE BUSINESS ACTIVITIES RECORDS

Name of entity where books and records are kept:
INSTITUTIONAL SHAREHOLDER SERVICES

Number and Street 1: Number and Street 2:
702 KING FARM BLVD. SUITE 300
City: State: Country: ZIP+4/Postal Code:
ROCKVILLE Maryland United States 20850-6536

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
646-680-6352

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
PROXY VOTING RECORDS

Name of entity where books and records are kept:
STATE STREET BANK AND TRUST

Number and Street 1: Number and Street 2:
ONE CONGRESS STREET SUITE 1
City: State: Country: ZIP+4/Postal Code:
BOSTON Massachusetts United States 02114-2016

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
617-786-3000

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Number and Street 1: Number and Street 2:
811 STATE ROUTE 33
City: State: Country: ZIP+4/Postal Code:
FREEHOLD New Jersey United States 07728-8431

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-934-3455

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
20 KIMBERLY RD
City: State: Country: ZIP+4/Postal Code:
EAST BRUNSWICK New Jersey United States 08816-2009

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-934-3453

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
6203 BINGLE RD
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77092-1307

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-934-3453

This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.

other.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
175 BEARFOOT RD
City: State: Country: ZIP+4/Postal Code:
NORTH BOROUGH Massachusetts United States 01532-1529

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-934-3453

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Name of entity where books and records are kept:
COREBRIDGE FINANANICAL, INC.

Number and Street 1: Number and Street 2:
30 HUDSON ST, 16TH FLOOR
City: State: Country: ZIP+4/Postal Code:
JERSEY CITY New Jersey United States 07302-4805

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
201-324-6300

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE KEPT BY THE INVESTMENT ADVISERS ACT AND/OR THE INVESTMENT COMPANY ACT OF 1940.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
202 WEST 38TH STREET
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77018-6610

If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
800-934-3453

This is (check one):
one of your branch offices or affiliates.

a third-party unaffiliated recordkeeper.

other.

SECTION 1.M. Registration with Foreign Financial Regulatory Authorities

No Information Filed

Item 2 SEC Registration/Reporting

Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for
SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2
should be provided for the filing adviser only.

A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an
annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2
provides information to help you determine whether you may affirmatively respond to each of these items.
You (the adviser):

(1) are a large advisory firm that either:

(a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or

(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating
amendment and is registered with the SEC;

(2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100
million (in U.S. dollars) and you are either:

(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place
of business; or

(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;

Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities
authority.

(3) Reserved

(4) have your principal office and place of business outside the United States;

(5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;

(6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the
Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under
management;

(7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption
in rule 203A-2(a);

(8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is
registered with the SEC, and your principal office and place of business is the same as the registered adviser;

If you check this box, complete Section 2.A.(8) of Schedule D.

(9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;

If you check this box, complete Section 2.A.(9) of Schedule D.

(10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);

If you check this box, complete Section 2.A.(10) of Schedule D.

(11) are an Internet adviser relying on rule 203A-2(e);

If you check this box, complete Section 2.A.(11) of Schedule D.

(12) have received an SEC order exempting you from the prohibition against registration with the SEC;

If you check this box, complete Section 2.A.(12) of Schedule D.
(13) are no longer eligible to remain registered with the SEC.

State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they
file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy
of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would
like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to
additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit
to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck
the box(es) next to those state(s).

Jurisdictions

AL IL NE SC
AK IN NV SD
AZ IA NH TN
AR KS NJ TX
CA KY NM UT
CO LA NY VT
CT ME NC VI
DE MD ND VA
DC MA OH WA
FL MI OK WV
GA MN OR WI
GU MS PA WY
HI MO PR
ID MT RI

If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that
state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).

SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control
with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser,
provide the following information:

Name of Registered Investment Adviser

CRD Number of Registered Investment Adviser

SEC Number of Registered Investment Adviser
-

SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days
If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration
within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will b e
deemed to have made the required representations. You must make both of these representations:
I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to
register with the SEC within 120 days after the date my registration with the SEC becomes effective.
I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section
203A(a) of the Advisers Act from registering with the SEC.

SECTION 2.A.(10) Multi-State Adviser
If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations
about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.

If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:
I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an
investment adviser with the state securities authorities in those states.
I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15
states to register as an investment adviser with the state securities authorities of those states.
If you are submitting your annual updating amendment, you must make this representation:
Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required
by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states.

SECTION 2.A.(11) Internet Adviser
If you are relying on rule 203A-2(e), the Internet adviser exemption from the prohibition on registration, you are required to make a representation about
your eligibility for SEC registration. By checking the appropriate box, you will be deemed to have made the required representation.

If you are applying for registration as an investment adviser with the SEC or changing your existing Item 2 response regarding your eligibility for SEC
registration, you must make this representation:
I will provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
If you are filing an annual updating amendment to your existing registration and are continuing to rely on the Internet adviser exemption for SEC
registration, you must make this representation:
I have provided and will continue to provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive
website.

SECTION 2.A.(12) SEC Exemptive Order
If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:

Application Number:
803-

Date of order:

Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation

Sole Proprietorship

Limited Liability Partnership (LLP)

Partnership

Limited Liability Company (LLC)

Limited Partnership (LP)

Other (specify):

If you are changing your response to this Item, see Part 1A Instruction 4.

B. In what month does your fiscal year end each year?
DECEMBER

C. Under the laws of what state or country are you organized?
State Country
Texas United States

If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the
name of the state or country where you reside.

If you are changing your response to this Item, see Part 1A Instruction 4.

Item 4 Successions
Yes No
A. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your
structure or legal status (e.g., form of organization or state of incorporation)?

If "yes", complete Item 4.B. and Section 4 of Schedule D.

B. Date of Succession: (MM/DD/YYYY)
If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.

SECTION 4 Successions

No Information Filed

Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation

Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making
regulatory policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5.

Employees

If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an
employee performs more than one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).

A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.
1700

B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
5
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
1381
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives?
1280
(4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives for an investment adviser other than you?
0
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
1213
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
0

In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on
your behalf.

Clients

In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship
with those investors.

C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services
during your most recently completed fiscal year?
0
(2) Approximately what percentage of your clients are non-United States persons?
0%

D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does
not include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of
1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment
Company Act of 1940, do not answer (1)(d) or (3)(d) below.

Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below)
attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check
Item 5.D.(2) rather than respond to Item 5.D.(1).

The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under
management reported in Item 5.F.(2)(c) below.

If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If
you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e),
and (f) as applicable.
(1) Number of (2) Fewer than (3) Amount of Regulatory Assets
Type of Client Client(s) 5 Clients under Management
(a) Individuals (other than high net worth individuals) $
(b) High net worth individuals $
(c) Banking or thrift institutions $
(d) Investment companies 36 $ 32,943,851,020
(e) Business development companies $
(f) Pooled investment vehicles (other than investment companies and $
business development companies)
(g) Pension and profit sharing plans (but not the plan participants or $
government pension plans)
(h) Charitable organizations $
(i) State or municipal government entities (including government pension $
plans)
(j) Other investment advisers $
(k) Insurance companies $
(l) Sovereign wealth funds and foreign official institutions $
(m) Corporations or other businesses not listed above $
(n) Other: $

Compensation Arrangements
E. You are compensated for your investment advisory services by (check all that apply):
(1) A percentage of assets under your management
(2) Hourly charges
(3) Subscription fees (for a newsletter or periodical)
(4) Fixed fees (other than subscription fees)
(5) Commissions
(6) Performance-based fees
(7) Other (specify):

Item 5 Information About Your Advisory Business - Regulatory Assets Under Management
Regulatory Assets Under Management
Yes No
F. (1) Do you provide continuous and regular supervisory or management services to securities portfolios?

(2) If yes, what is the amount of your regulatory assets under management and total number of accounts?
U.S. Dollar Amount Total Number of Accounts
Discretionary: (a) $ 32,943,851,020 (d) 36
Non-Discretionary: (b) $ 0 (e) 0
Total: (c) $ 32,943,851,020 (f) 36

Part 1A Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when
completing this Item.

(3) What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who
are non-United States persons?
$0

Item 5 Information About Your Advisory Business - Advisory Activities
Advisory Activities
G. What type(s) of advisory services do you provide? Check all that apply.
(1) Financial planning services
(2) Portfolio management for individuals and/or small businesses
(3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to
section 54 of the Investment Company Act of 1940)
(4) Portfolio management for pooled investment vehicles (other than investment companies)
(5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and
other pooled investment vehicles)
(6) Pension consulting services
(7) Selection of other advisers (including private fund managers)
(8) Publication of periodicals or newsletters
(9) Security ratings or pricing services
(10) Market timing services
(11) Educational seminars/workshops
(12) Other(specify):

Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the
Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or
investment companies to which you provide advice in Section 5.G.(3) of Schedule D.

H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?
0

1 - 10
11 - 25
26 - 50
51 - 100
101 - 250
251 - 500
More than 500
If more than 500, how many?
(round to the nearest 500)

In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship
with those investors.

Yes No
I. (1) Do you participate in a wrap fee program?

(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:
(a) sponsor to a wrap fee program
$
(b) portfolio manager for a wrap fee program?
$
(c) sponsor to and portfolio manager for the same wrap fee program?
$

If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b).

If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D.

If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a
wrap fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2).
Yes No
J. (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of
investments?
(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your
regulatory assets under management?

K. Separately Managed Account Clients
Yes No
(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately
managed account clients)?

If yes, complete Section 5.K.(1) of Schedule D.

(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?

If yes, complete Section 5.K.(2) of Schedule D.

(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?

If yes, complete Section 5.K.(2) of Schedule D.

(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold
ten percent or more of this remaining amount of regulatory assets under management?

If yes, complete Section 5.K.(3) of Schedule D for each custodian.

L. Marketing Activities
Yes No
(1) Do any of your advertisements include:
(a) Performance results?

(b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))?

(d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))?

(e) Third-party ratings?

(2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in
connection with the use of testimonials, endorsements, or third-party ratings?

(3) Do any of your advertisements include hypothetical performance ?

(4) Do any of your advertisements include predecessor performance ?

SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies

If you check Item 5.G.(3), what is the SEC file number (811 or 814 number) of each of the registered investment companies and business development
companies to which you act as an adviser pursuant to an advisory contract? You must complete a separate Schedule D Section 5.G.(3) for each registered
investment company and business development company to which you act as an adviser.

SEC File Number
811 - 03738

Provide the regulatory assets under management of all parallel managed accounts related to a registered investment company (or series thereof) or
business development company that you advise.

No Information Filed

SECTION 5.I.(2) Wrap Fee Programs

No Information Filed

SECTION 5.K.(1) Separately Managed Accounts
After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of
this remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under
management, complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b).

Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.

If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you
subadvise.

End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the
date six months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent.

Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in
those categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of
deposit, bankers' acceptances and similar bank instruments.

Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal
methodologies and the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are
consistently applied and consistent with information you report internally and to current and prospective clients. However, you should not double count
assets, and your responses must be consistent with any instructions or other guidance relating to this Section.

(a) Asset Type Mid-year End of year
(i) Exchange-Traded Equity Securities % %
(ii) Non Exchange-Traded Equity Securities % %
(iii) U.S. Government/Agency Bonds % %
(iv) U.S. State and Local Bonds % %
(v) Sovereign Bonds % %
(vi) Investment Grade Corporate Bonds % %
(vii) Non-Investment Grade Corporate Bonds % %
(viii) Derivatives % %
(ix) Securities Issued by Registered Investment Companies or Business Development Companies % %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business % %
Development Companies)
(xi) Cash and Cash Equivalents % %
(xii) Other % %
Generally describe any assets included in "Other"

(b) Asset Type End of year
(i) Exchange-Traded Equity Securities %
(ii) Non Exchange-Traded Equity Securities %
(iii) U.S. Government/Agency Bonds %
(iv) U.S. State and Local Bonds %
(v) Sovereign Bonds %
(vi) Investment Grade Corporate Bonds %
(vii) Non-Investment Grade Corporate Bonds %
(viii) Derivatives %
(ix) Securities Issued by Registered Investment Companies or Business Development Companies %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development %
Companies)
(xi) Cash and Cash Equivalents %
(xii) Other %
Generally describe any assets included in "Other"

SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives

No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)

If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your
regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete
Question (b).

(a) In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately
managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date
used to calculate your regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before
the end of year date.

In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross
notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the
dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.

In column 2, provide the dollar amount of borrowings for the accounts included in column 1.

In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts
included in column 1 with respect to each category of derivatives specified in 3(a) through (f).

You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of
less than $10,000,000.

Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.

(i) Mid-Year

Gross Notional (1) Regulatory Assets (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(a) Interest (b) Foreign
Rate Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ $ % % % % % %

10-149% $ $ % % % % % %

150% or more $ $ % % % % % %

Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.

(ii) End of Year

10-149% $ $ % % % % % %

150% or more $ $ % % % % % %

(b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your
regulatory assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you
should only provide information with respect to the portion of the account that you subadvise.

In column 2, provide the dollar amount of borrowings for the accounts included in column 1.

You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of
less than $10,000,000.

Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.

Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings
Less than 10% $ $

10-149% $ $

150% or more $ $

SECTION 5.K.(3) Custodians for Separately Managed Accounts

No Information Filed

Item 6 Other Business Activities

In this Item, we request information about your firm's other business activities.

A. You are actively engaged in business as a (check all that apply):
(1) broker-dealer (registered or unregistered)
(2) registered representative of a broker-dealer
(3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(4) futures commission merchant
(5) real estate broker, dealer, or agent
(6) insurance broker or agent
(7) bank (including a separately identifiable department or division of a bank)
(8) trust company
(9) registered municipal advisor
(10) registered security-based swap dealer
(11) major security-based swap participant
(12) accountant or accounting firm
(13) lawyer or law firm
(14) other financial product salesperson (specify):

If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.
Yes No
B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?

(2) If yes, is this other business your primary business?

If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
Yes No
(3) Do you sell products or provide services other than investment advice to your advisory clients?

If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.

SECTION 6.A. Names of Your Other Businesses

No Information Filed

SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):
COMPANY ISSUES, BUT DOES NOT SELL, FIXED AND VARIABLE ANNUITY PRODUCTS. THE PRODUCTS ARE SOLD THROUGH BOTH AFFILIATED AND INDEPENDENT
BROKER/DEALERS.

If you engage in that business under a different name, provide that name:

SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above.

If you engage in that business under a different name, provide that name:

Item 7 Financial Industry Affiliations

In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may
occur between you and your clients.

A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your
advisory affiliates and any person that is under common control with you.
You have a related person that is a (check all that apply):
(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
(2) other investment adviser (including financial planners)
(3) registered municipal advisor
(4) registered security-based swap dealer
(5) major security-based swap participant
(6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(7) futures commission merchant
(8) banking or thrift institution
(9) trust company
(10) accountant or accounting firm
(11) lawyer or law firm
(12) insurance company or agency
(13) pension consultant
(14) real estate broker or dealer
(15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles

Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a
broker-dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your
firm's employees who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2).

Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete
Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser.
For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of
Schedule D.

You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with
advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the
related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the
related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.

You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your
clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be
operationally independent under rule 206(4)-2 of the Advisers Act.

SECTION 7.A. Financial Industry Affiliations

Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.

1. Legal Name of Related Person:
VALIC TRUST COMPANY

2. Primary Business Name of Related Person:
VALIC TRUST COMPANY

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other

4. Related Person's
(a) CRD Number (if any):

(b) CIK Number(s) (if any):
No Information Filed

5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?

7. Are you and the related person under common control?

8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not
required to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?

(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?

12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
VALIC FINANCIAL ADVISORS, INC.

2. Primary Business Name of Related Person:
VALIC FINANCIAL ADVISORS, INC.

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 54952
or
Other

4. Related Person's
(a) CRD Number (if any):
42803
(b) CIK Number(s) (if any):
No Information Filed

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
AMERICAN GENERAL LIFE INSURANCE COMPANY

2. Primary Business Name of Related Person:
AMERICAN GENERAL LIFE INSURANCE COMPANY

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other

4. Related Person's
(a) CRD Number (if any):

(b) CIK Number(s) (if any):
No Information Filed

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
COREBRIDGE CAPITAL SERVICES, INC.
2. Primary Business Name of Related Person:
COREBRIDGE CAPITAL SERVICES, INC.

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
8 - 28733
or
Other

4. Related Person's
(a) CRD Number (if any):
13158
(b) CIK Number(s) (if any):
No Information Filed

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK

2. Primary Business Name of Related Person:
THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other

4. Related Person's
(a) CRD Number (if any):

(b) CIK Number(s) (if any):
No Information Filed

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

12. Do you and the related person share the same physical location?

Item 7 Private Fund Reporting

Yes No

B. Are you an adviser to any private fund?

If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next
sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt
reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section
7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must,
instead, complete Section 7.B.(2) of Schedule D.

In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical
code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or
designation in place of the fund's name.
SECTION 7.B.(1) Private Fund Reporting

No Information Filed

SECTION 7.B.(2) Private Fund Reporting

No Information Filed

Item 8 Participation or Interest in Client Transactions

In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which
conflicts of interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation
and interest that you expect to engage in during the next year.

Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.

Proprietary Interest in Client Transactions
A. Do you or any related person: Yes No
(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?

(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?

(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary
(ownership) interest (other than those mentioned in Items 8.A.(1) or (2))?

Sales Interest in Client Transactions
B. Do you or any related person: Yes No
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory
client securities are sold to or bought from the brokerage customer (agency cross transactions)?
(2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for
which you or any related person serves as underwriter or general or managing partner?
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than
the receipt of sales commissions as a broker or registered representative of a broker-dealer)?

Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the: Yes No
(1) securities to be bought or sold for a client's account?

(2) amount of securities to be bought or sold for a client's account?

(3) broker or dealer to be used for a purchase or sale of securities for a client's account?

(4) commission rates to be paid to a broker or dealer for a client's securities transactions?

D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?

E. Do you or any related person recommend brokers or dealers to clients?

F. If you answer "yes" to E. above, are any of the brokers or dealers related persons?

G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party
("soft dollar benefits") in connection with client securities transactions?
(2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under
section 28(e) of the Securities Exchange Act of 1934?

H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?

(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for
the firm (cash or non-cash compensation in addition to the employee's regular salary)?

I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related
person) for client referrals?
In your response to Item 8.I., do not include the regular salary you pay to an employee.

In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received
from (in answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client
referrals.
Item 9 Custody

In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the
Investment Company Act of 1940) assets and about your custodial practices.

A. (1) Do you have custody of any advisory clients': Yes No
(a) cash or bank accounts?

(b) securities?

If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees
directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you
have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.

(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which
you have custody:

U.S. Dollar Amount Total Number of Clients
(a) $ (b)

If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not
include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in
connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2).
Instead, include that information in your response to Item 9.B.(2).

B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a) cash or bank accounts?

(b) securities?

You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).

(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which
your related persons have custody:

U.S. Dollar Amount Total Number of Clients
(a) $ (b)

C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following
that apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements
are distributed to the investors in the pools.
(3) An independent public accountant conducts an annual surprise examination of client funds and securities.
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons
are qualified custodians for client funds and securities.

If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare
an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this
information with respect to the private funds you advise in Section 7.B.(1) of Schedule D).

D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian

(2) your related person(s) act as qualified custodian(s)

If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule
206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent
under rule 206(4)-2 of the Advisers Act.

E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last
fiscal year, provide the date (MM/YYYY) the examination commenced:

F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act
as qualified custodians for your clients in connection with advisory services you provide to clients?

SECTION 9.C. Independent Public Accountant
No Information Filed

Item 10 Control Persons

In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10
should be provided for the filing adviser only.

If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners
and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported
on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?

If yes, complete Section 10.A. of Schedule D.

B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please complete Section 10.B. of Schedule D.

SECTION 10.A. Control Persons

You must complete a separate Schedule D Section 10.A. for each control person not named in Item 1.A. or Schedules A, B, or C that directly or indirectly
controls your management or policies.

Firm or Organization Name
NIPPON LIFE INSURANCE COMPANY

CRD Number (if any)

Effective Date Termination Date
01/22/2026

Business Address:
Number and Street 1 Number and Street 2
1-6-6 MARUNOUCHI CHIYODA-KU
City State Country ZIP+4/Postal Code
TOKYO Japan 100-8288

If this address is a private residence, check this box:

Briefly describe the nature of the control:
ALTHOUGH NIPPON LIFE INSURANCE COMPANY ("NIPPON") MEETS THE TECHNICAL CRITERIA TO BE PRESUMED A CONTROL PERSON FOR PURPOSES OF
FORM ADV, IT DOES NOT IN FACT HAVE THE ABILITY TO CONTROL THE INVESTMENT ADVISER. THE BOARD OF DIRECTORS OF COREBRIDGE FINANCIAL, INC.
("CRBG") HAS SET THE SIZE OF THE CRBG BOARD AT 11 MEMBERS AND PERMITTED NIPPON TO DESIGNATE 3 OUT OF 11 MEMBERS OF THE CRBG BOARD. AS A
RESULT, NIPPON HAS THE RIGHT TO DESIGNATE MORE THAN 25% (BUT A MINORITY OVERALL) OF THE MEMBERS OF THE CRBG BOARD.

SECTION 10.B. Control Person Public Reporting Companies

B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting
company):
(1) Full legal name of the public reporting company: COREBRIDGE FINANCIAL,
INC.
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting 1889539
company):

Item 11 Disclosure Information

In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to
determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an
investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than
one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an
umbrella registration.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all
of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you.
If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.

If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years
following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your
disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of
calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary
orders, judgments, or decrees lapsed.

You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.

Yes No
Do any of the events below involve you or any of your supervised persons?

For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?

(2) been charged with any felony?

If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to
charges that are currently pending.

B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving:
investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?

If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to
charges that are currently pending.

For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?

(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?

(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?

(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?

D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?

(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?

(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business
denied, suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?

(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory
affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?

E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?

(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule
violation" under a plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you
or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?

F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or
suspended?

G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
11.D., or 11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?

(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?

(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by
a state or foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?

Item 12 Small Businesses

The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine
whether you meet the definition of "small business" or "small organization" under rule 0-7.

Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets
under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a
current state registration, or switching from SEC to state registration.

For purposes of this Item 12 only:

Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total
assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with
subsidiaries included, if that amount is larger).
Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by
contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent
or more of the profits, of another person is presumed to control the other person.

Yes No
A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?

If "yes," you do not need to answer Items 12.B. and 12.C.

B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV)
of $25 million or more on the last day of its most recent fiscal year?
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal
year?

C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in
response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year?
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the
last day of its most recent fiscal year?

Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive
officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is
required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar
status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a
public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a
class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild,
grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-
law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to
purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has
contributed, 5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5%
or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No

4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or
member; and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: DE/FE/I Title or Status Date Title or Ownership Control PR CRD No. If None: S.S. No.
Last Name, First Name, Middle Status Acquired Code Person and Date of Birth, IRS Tax
Name) MM/YYYY No. or Employer ID No.
FIEDLER, TERRI I DIRECTOR AND PRESIDENT OF GROUP 12/2022 NA Y N 2373060
RETIREMENT
NOVAK, JONATHAN I DIRECTOR AND PRESIDENT OF 03/2023 NA Y N 4253567
INSTITUTIONAL MARKETS
Longino, Lisa I DIRECTOR, EXECUTIVE VICE PRESIDENT 03/2023 NA Y N 7719315
AND CHIEF INVESTMENT OFFICER
FILIAGGI, CHRISTOPHER, P I DIRECTOR, SENIOR VICE PRESIDENT AND 02/2024 NA Y N 7880806
CHIEF FINANCIAL OFFICER
PINSKY, BRYAN I DIRECTOR 02/2024 NA Y N 5260855
SMITH, CHRISTOPHER, B I CHAIRMAN OF THE BOARD OF DIRECTORS 02/2024 NA Y N 7882459
AND PRESIDENT
DITILLO, DAVID I DIRECTOR, EXECUTIVE VICE PRESIDENT 02/2024 NA Y N 7889155
AND CHIEF INFORMATION OFFICER
GINGRICH, EMILY, WHITNEY I DIRECTOR, SENIOR VICE PRESIDENT, 02/2025 NA Y N 5244334
CHIEF ACTUARY AND CORPORATE
ILLUSTRATION ACTUARY
AMERICAN GENERAL LIFE DE 100% STOCKHOLDER 06/2025 E Y N
INSURANCE COMPANY
Robins, Melissa, Kay I INVESTMENT ADVISER CHIEF 01/2026 NA Y N 8206038
COMPLIANCE OFFICER
Tarnow, Eric, G. I DIRECTOR 12/2025 NA N N 8243160
REZNIK, MALLARY I SENIOR VICE PRESIDENT, GENERAL 12/2025 NA N N 8241950
COUNSEL AND ASSISTANT SECRETARY

Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct
the sale of, 25% or more of a class of a voting security of that corporation;

For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence;
or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon
dissolution, or have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have
contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of
the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or
members, the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Entity in Which Status Date Status Ownership Control PR CRD No. If None: S.S. No.
Name, First Name, Middle Name) Interest is Owned Acquired Code Person and Date of Birth, IRS Tax
MM/YYYY No. or Employer ID No.
COREBRIDGE LIFE HOLDINGS, INC. DE AGC LIFE SHAREHOLDER 01/1969 E Y N
INSURANCECOMPANY
COREBRIDGE FINANCIAL, INC. DE COREBRIDGE LIFE SHAREHOLDER 04/2012 E Y Y
HOLDINGS, INC.
AGC LIFE INSURANCECOMPANY DE AMERICAN GENERAL SHAREHOLDER 12/2012 E Y N
LIFE INSURANCE
COMPANY

Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.

Schedule R

No Information Filed

DRP Pages

CRIMINAL DISCLOSURE REPORTING PAGE (ADV)

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.A. or
OR
11.B. of Form ADV.

Criminal
Check item(s) being responded to:
11.A(1) 11.A(2) 11.B(1) 11.B(2)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE

CRD 6007122
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: MOELLER, BRENT, ARNOLD
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship.

2. Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number).

3. Event Disclosure Detail (Use this for both organizational and individual charges.)

A. Date First Charged (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:
B. Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related).
C. Did any of the Charge(s) within the Event involve a ?
felony Yes No

D. Current status of the Event? Pending On Appeal Final
E. Event Status Date (complete unless status is Pending) (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.

5. Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.A. or
OR
11.B. of Form ADV.

Criminal
Check item(s) being responded to:
11.A(1) 11.A(2) 11.B(1) 11.B(2)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 6903293
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: SKRABANEK, CASEY, LANE
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number).

3. Event Disclosure Detail (Use this for both organizational and individual charges.)

A. Date First Charged (MM/DD/YYYY):

D. Current status of the Event? Pending On Appeal Final
E. Event Status Date (complete unless status is Pending) (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

No Information Filed

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
WEST VIRGINIA SECURITIES COMMISSION

2. Principal Sanction:
Cease and Desist
Other Sanctions:
REVOCATION, SUSPENSION (PENDING) AND ADMINISTRATIVE ASSESSMENT OF $50,000 PER SUMMARY ORDER (PENDING).

3. Date Initiated (MM/DD/YYYY):

08/06/2015 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
08-1728-9

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
AUGUST 6, 2015: IN TWENTY-FOUR SEPARATE SUMMARY ORDERS (THE "SUMMARY ORDERS"), THE WEST VIRGINIA STATE AUDITOR AND COMMISSIONER
OF SECURITIES (THE "STATE AUDITOR") HAS ALLEGED THAT BETWEEN 1990 TO 1994: (1) VALIC ACTED AS AN INVESTMENT ADVISER BY CONDUCTING
INVESTMENT ADVISORY SERVICES IN THE STATE OF WEST VIRGINIA ("WV") WITHOUT THE BENEFIT OF REGISTRATION IN VIOLATION OF WV CODE §32
2201(C); (2) A VALIC ADVERTISEMENT HAD NOT BEEN FILED WITH THE COMMISSION BEFORE IT WAS DISTRIBUTED IN VIOLATION OF WV CODE §324
403; (3) VALIC AND ITS AGENT DEFRAUDED INVESTORS BY MISLEADING THEM TO SWITCH FROM WV'S DEFINED BENEFIT PLAN TO THE DEFINED
CONTRIBUTION PLAN, BY MISREPRESENTING MATERIAL FACTS AND IMPLYING THEY WERE REPRESENTATIVES OF THE SCHOOL BOARD OR THE STATE IN
VIOLATION OF WV CODES §321101 AND §3211 02(A); (5) STATEMENTS AND/OR OMISSIONS MADE A VALIC AGENT IN CONNECTION WITH THE
OFFER, SALE, OR PURCHASE OF ANY SECURITY DIRECTLY OR INDIRECTLY WERE MISLEADING AND CONSTITUTED A SCHEME TO DEFRAUD WV
RESIDENTS IN VIOLATION OF WV CODE §321101 ET SEQ.; AND (5) THE FAILURE OF VALIC'S AGENT TO DISCLOSE TO HIS CLIENT THAT HE WAS
EMPLOYED AND CONTROLLED BY VALIC WHILE ASSISTING IN HIS CLIENT'S RETIREMENT PLAN CONSTITUTES A DISHONEST OR UNETHICAL PRACTICE IN
THE SECURITIES BUSINESS IN ACCORDANCE WITH WV CODE §322204(B)(23).

8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Vacated

11. Resolution Date (MM/DD/YYYY):

05/03/2019 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
CEASE AND DESIST ORDER WAS VACATED ON MAY 3, 2019
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
CEASE AND DESIST ORDER WAS VACATED ON MAY 3, 2019

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 24, 2015, VALIC SENT WRITTEN RESPONSES TO THE WV STATE AUDITOR, WHICH RESPONSE SETS FORTH VALIC'S OBJECTIONS TO THE
SUMMARY ORDERS. BASED ON THOSE OBJECTIONS, VALIC HAS REQUESTED THAT THE SUMMARY ORDERS BE WITHDRAWN OR, ALTERNATIVELY, THAT AN
ADMINISTRATIVE HEARING BE SCHEDULED AS SOON AS POSSIBLE SO THAT VALIC MAY PRESENT ITS COMPLETE RESPONSE TO THE ALLEGATIONS IN
THE SUMMARY ORDERS. VALIC'S OBJECTIONS TO THE SUMMARY ORDERS ARE AS FOLLOWS: (1) VALIC IS CONCERNED WITH THE CIRCUMSTANCES IN
WHICH THE SUMMARY ORDERS WERE TRANSMITTED TO VALIC. THE SUMMARY ORDERS WERE TRANSMITTED TO VALIC BY OUTSIDE COUNSEL ("WV
COUNSEL"), WHICH HAD BEEN REPRESENTING THE WV INVESTMENT MANAGEMENT BOARD (IMB) AND THE CONSOLIDATED PUBLIC RETIREMENT BOARD
(CPRB) IN CIVIL LITIGATION AGAINST VALIC. ADDITIONALLY, SHORTLY BEFORE A COURT-ORDERED MEDIATION IN THAT ACTION IN MAY 2015, WV
COUNSEL HAD THREATENED VALIC WITH SERVICE OF THE SUMMARY ORDERS, NOTWITHSTANDING THAT THE RELEVANT INQUIRY, WHICH DATED BACK
TO 2008, HAD LONG BEEN ENTIRELY DORMANT. VALIC FURTHER ASSERTS THAT THE SUMMARY ORDERS WERE POLITICALLY MOTIVATED AND NOT BASED
ON ANY LEGITIMATE CONCERNS ABOUT THE LEGALITY OF VALIC'S CONDUCT. THUS, IT IS VALIC'S BELIEF THAT THE SUMMARY ORDERS REPRESENTED
AN IMPROPER ATTEMPT BY WV COUNSEL TO USE AUTHORITY VESTED IN HIM BY THE STATE TO EXERT LEVERAGE IN CIVIL LITIGATION (IN WHICH VALIC
HAS NOW ENTIRELY PREVAILED). (2) VALIC ALSO ASSERTS THAT THE ALLEGATIONS IN THE SUMMARY ORDERS ARE COMPLETELY LACKING OF MERIT
AND THAT THE DEFICIENCIES IN THE SUMMARY ORDERS ARE AS FOLLOWS: (I) THE COMMISSION LACKS JURISDICTION OVER VALIC'S PRODUCTS AND
PRACTICES; (II) VALIC DID NOT OFFER INVESTMENT ADVICE, MUCH LESS DO SO AS AN UNREGISTERED INVESTMENT ADVISER RECEIVING SPECIAL
COMPENSATION; (III) THE CONDUCT ALLEGED OCCURRED IN THE 1990S AND, EVEN IF ACCURATELY DESCRIBED, (WHICH IT IS NOT), ANY CLAIMS
BASED ON THAT CONDUCT WOULD BE TIME-BARRED BY APPLICABLE STATUTES OF LIMITATIONS; AND (IV) SEVERAL OF THE STATUTORY PROVISIONS
CITED IN THE SUMMARY ORDERS WERE NOT PASSED INTO LAW UNTIL AFTER THE ALLEGED CONDUCT BY VALIC'S REPRESENTATIVES AND THEREFORE
CANNOT APPLY TO THAT CONDUCT. THE WEST VIRGINIA IMB AND CPRB CIVIL LITIGATION REFERENCED ABOVE WAS DECIDED ENTIRELY IN VALIC'S
FAVOR IN AN APRIL 28, 2017 ARBITRAL DECISION, WHICH WAS AFFIRMED ON APPEAL BY THE WEST VIRGINIA SUPREME COURT ON JUNE 5, 2018
(WITH A MOTION FOR REARGUMENT HAVING BEEN DENIED ON NOVEMBER 14, 2018 AND NO FURTHER APPEAL HAVING BEEN TAKEN). THE CEASE AND
DESIST ORDER WAS VACATED ON MAY 3, 2019.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")

2. Principal Sanction:
Censure
Other Sanctions:
$1,750,000 FINE

3. Date Initiated (MM/DD/YYYY):

11/28/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
NO. 2014042360001

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
VALIC FINANCIAL ADVISORS, INC.

6. Principal Product Type:
Annuity(ies) - Variable
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINANCIAL REGULATORY AUTHORITY'S (FINRA) FINDINGS, VALIC FINANCIAL ADVISORS, INC. ("FIRM")
SUBMITTED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") FOR THE PURPOSE OF PROPOSING A SETTLEMENT OF THE ALLEGED RULE
VIOLATIONS DESCRIBED BELOW. FINRA ALLEGED VIOLATIONS OF NASD RULE 3010(A)/(B) AND FINRA RULES 2010, 2330(C), (D) AND (E), 3110(A)/(B)
RELATING TO ALLEGED FAILURES TO (1) HAVE A REASONABLE SYSTEM OR PROCESS/PROCEDURES DESIGNED TO ADDRESS, ANALYZE OR REVIEW THE
CONFLICTS OF INTEREST IN ITS COMPENSATION PROGRAM OR TO ENSURE THAT BALANCED DISCLOSURES WAS PROVIDED TO THE INVESTORS
REGARDING SUCH COMPENSATION PROGRAM, (2) TO MAINTAIN ADEQUATE SYSTEMS AND PROCEDURES TO SUPERVISE THE SALE OF VARIABLE
ANNUITIES TO RETAIL BROKERAGE CUSTOMERS, (3) MAINTAIN SUPERVISORY PROCEDURES AND TRAINING MATERIALS THAT PROVIDE REGISTERED
REPRESENTATIVES AND PRINCIPALS GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VARIABLE ANNUITY SHARE CLASSES,
INCLUDING L-SHARE VARIABLE ANNUITIES, (4) ENFORCE SUPERVISORY PROCEDURES REQUIRING THE THAT CERTAIN EMAILS FLAGGED BY ITS EMAIL
SURVEILLANCE SYSTEM BE REVIEWED BY DESIGNATED FIRM SUPERVISORS, (5) ESTABLISH A REASONABLE SYSTEM AND PROCEDURES TO SUPERVISE
ITS COMPLAINT REPORTING RESPONSIBILITIES (ALLEGED VIOLATION OF FINRA RULES 4530, 1122 AND 2010 AND FINRA BY-LAWS ARTICLE V, SECTION
2 AND 3), AND (6) FAILED TO ISSUE ACCOUNT NOTICES AT ACCOUNT OPENING AND THEN ON 36-MONTH INTERVALS FOR CERTAIN BROKERAGE
CUSTOMERS (ALLEGED VIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3(A)(17)(I)(B)(1) THEREUNDER,
NASD RULES 3110 AND 2110, AND FINRA RULES 4511 AND 2010).

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):

11/28/2016 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 1,750,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, VALIC FINANCIAL ADVISORS, INC. ("VFA") CONSENTED TO THE DESCRIBED SANCTIONS AND
TO THE ENTRY OF FINDINGS. THEREFORE, VFA WAS CENSURED AND FINED $1,750,000.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINANCIAL REGULATORY AUTHORITY'S (FINRA) FINDINGS, VALIC FINANCIAL ADVISORS, INC. ("FIRM")
SUBMITTED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") FOR THE PURPOSE OF PROPOSING A SETTLEMENT OF THE ALLEGED RULE
VIOLATIONS DESCRIBED BELOW. FINRA ALLEGED VIOLATIONS OF NASD RULE 3010(A)/(B) AND FINRA RULES 2010, 2330(C), (D) AND (E), 3110(A)/(B)
RELATING TO ALLEGED FAILURES TO (1) HAVE A REASONABLE SYSTEM OR PROCESS/PROCEDURES DESIGNED TO ADDRESS, ANALYZE OR REVIEW THE
CONFLICTS OF INTEREST IN ITS COMPENSATION PROGRAM OR TO ENSURE THAT BALANCED DISCLOSURES WAS PROVIDED TO THE INVESTORS
REGARDING SUCH COMPENSATION PROGRAM, (2) TO MAINTAIN ADEQUATE SYSTEMS AND PROCEDURES TO SUPERVISE THE SALE OF VARIABLE
ANNUITIES TO RETAIL BROKERAGE CUSTOMERS, (3) MAINTAIN SUPERVISORY PROCEDURES AND TRAINING MATERIALS THAT PROVIDE REGISTERED
REPRESENTATIVES AND PRINCIPALS GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VARIABLE ANNUITY SHARE CLASSES,
INCLUDING L-SHARE VARIABLE ANNUITIES, (4) ENFORCE SUPERVISORY PROCEDURES REQUIRING THE THAT CERTAIN EMAILS FLAGGED BY ITS EMAIL
SURVEILLANCE SYSTEM BE REVIEWED BY DESIGNATED FIRM SUPERVISORS, (5) ESTABLISH A REASONABLE SYSTEM AND PROCEDURES TO SUPERVISE
ITS COMPLAINT REPORTING RESPONSIBILITIES (ALLEGED VIOLATION OF FINRA RULES 4530, 1122 AND 2010 AND FINRA BY-LAWS ARTICLE V, SECTION
2 AND 3), AND (6) FAILED TO ISSUE ACCOUNT NOTICES AT ACCOUNT OPENING AND THEN ON 36-MONTH INTERVALS FOR CERTAIN BROKERAGE
CUSTOMERS (ALLEGED VIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3(A)(17)(I)(B)(1) THEREUNDER,
NASD RULES 3110 AND 2110, AND FINRA RULES 4511 AND 2010).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF OKLAHOMA INSURANCE DEPARTMENT

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

06/14/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
16-0572-DEN

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 6, 2016, VALIC FINANCIAL ADVISORS, INC. ("VFA") FILED AN INSURANCE AGENCY APPLICATION ON BEHALF OF VFA IN THE STATE OF
OKLAHOMA. DUE TO AN ADMINISTRATIVE ERROR, THE APPLICATION OMITTED CERTAIN FINRA REGULATORY ACTIONS. VFA AMENDED ITS APPLICATION
ON JUNE 3. ON JUNE 14, THE STATE ISSUED AN ADMINISTRATIVE FINE AGAINST VFA IN THE AMOUNT OF $300 FOR OMITTING THE REGULATORY EVENT
IN ITS APPLICATION.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Other

11. Resolution Date (MM/DD/YYYY):

06/30/2016 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 300.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 6, 2016, VALIC FINANCIAL ADVISORS, INC. ("VFA") FILED AN INSURANCE AGENCY APPLICATION ON BEHALF OF VFA IN THE STATE OF
OKLAHOMA. DUE TO AN ADMINISTRATIVE ERROR, THE APPLICATION OMITTED CERTAIN FINRA REGULATORY ACTIONS. VFA AMENDED ITS APPLICATION
ON JUNE 3. ON JUNE 14, THE STATE ISSUED AN ADMINISTRATIVE FINE AGAINST VFA IN THE AMOUNT OF $300 FOR OMITTING THE REGULATORY EVENT
IN ITS APPLICATION.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ALASKA DIVISION OF INSURANCE

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

10/07/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
100130340

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

10/07/2016 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
LOUISIANA DEPARTMENT OF INSURANCE

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

11/07/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NORTH CAROLINA DEPARTMENT OF INSURANCE

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

12/13/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
1000474400

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

01/10/2017 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
VIRGINIA BUREAU OF INSURANCE

2. Principal Sanction:
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

11/29/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
68901

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

12/04/2016 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
TENNESSEE DIVISION OF FINANCE

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

12/05/2017 Exact Explanation
If not exact, provide explanation:
ON OR ABOUT 12/05/2017, VFA RECEIVED FORMAL NOTICE OF THE TENNESSEE DIVISION OF INSURANCE'S INTENTION TO INITIATE DISCIPLINARY
PROCEEDINGS AGAINST VFA.

4. Docket/Case Number:
12.04-149432J

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

01/22/2018 Exact Explanation
If not exact, provide explanation:
VFA SIGNED THE FINAL ORDER AND PAID THE FINE.

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE
CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

01/23/2017 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
AGN266722

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

04/07/2017 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/23/2017 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

06/28/2017 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES ENFORCEMENT BRANCH ("SEB") OF THE HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):

06/03/2019 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 3, 2019, WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM SETTLED A MATTER WITH THE
SECURITIES ENFORCEMENT BRANCH ("SEB") OF THE HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS. AS PART OF THE SETTLEMENT, THE
FIRM ENTERED INTO A CONSENT ORDER WITH THE SEB (THE "CONSENT ORDER"), WHICH STATES THAT THE FIRM FAILED TO SUPERVISE A REGISTERED
REPRESENTATIVE WHO HAD SUBMITTED A TRANSACTION WITHOUT PROPER CUSTOMER AUTHORIZATION. PURSUANT TO THE CONSENT ORDER, THE
FIRM PAID A FINE OF $10,000.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

06/03/2019 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ON JUNE 3, 2019, WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM SETTLED A MATTER WITH THE
SECURITIES ENFORCEMENT BRANCH ("SEB") OF THE HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS. AS PART OF THE
SETTLEMENT, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE SEB (THE "CONSENT ORDER"), WHICH STATES THAT THE FIRM FAILED TO
SUPERVISE A REGISTERED REPRESENTATIVE WHO HAD SUBMITTED A TRANSACTION WITHOUT PROPER CUSTOMER AUTHORIZATION. PURSUANT
TO THE CONSENT ORDER, THE FIRM PAID A FINE OF $10,000.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JUNE 3, 2019, WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR CONCLUSIONS OF LAW, THE FIRM SETTLED A MATTER WITH THE
SECURITIES ENFORCEMENT BRANCH ("SEB") OF THE HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS. AS PART OF THE SETTLEMENT, THE
FIRM ENTERED INTO A CONSENT ORDER WITH THE SEB (THE "CONSENT ORDER"), WHICH STATES THAT THE FIRM FAILED TO SUPERVISE A REGISTERED
REPRESENTATIVE WHO HAD SUBMITTED A TRANSACTION WITHOUT PROPER CUSTOMER AUTHORIZATION. PURSUANT TO THE CONSENT ORDER, THE
FIRM PAID A FINE OF $10,000.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
MATTER NO. 2018060548501

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE
No Information Filed

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

12/31/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2021-0089-S

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
INDIVIDUAL, DEFERRED, FIXED AND VARIABLE ANNUITIES, AND GROUP FIXED ANNUITIES.

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN SEPTEMBER 2021, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY ("VALIC") PAID A $230,820.00 ADMINISTRATIVE FINE TO THE NEW YORK
STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT
EXAMINATION OF THE COMPANY'S INDIVIDUAL AND GROUP ANNUITY BUSINESSES, COVERING THE TIME PERIOD OF JANUARY 1, 2012 TO DECEMBER 31,
2016.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

09/21/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 230,820.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
REMEDIATION OF EXCEPTIONS FOUND AND A REPORT TO THE DEPARTMENT WITHIN ONE MONTH OF THE CONSENT ORDER INDICATING
COMPLIANCE.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $230,820.00 PAID ON 09/17/2021. THE FULL FINE AMOUNT WAS LEVIED AGAINST THE VARIABLE ANNUITY LIFE INSURANCE
COMPANY ("VALIC") WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SEPTEMBER 2021, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY ("VALIC") PAID A $230,820.00 ADMINISTRATIVE FINE TO THE NEW YORK
STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT
EXAMINATION OF THE COMPANY'S INDIVIDUAL AND GROUP ANNUITY BUSINESSES, COVERING THE TIME PERIOD OF JANUARY 1, 2012 TO DECEMBER 31,
2016.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 42803
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VALIC FINANCIAL ADVISORS,
INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD 4747512
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: LOUDENBACK, DEREK,
JAMISON
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: VARIABLE ANNUITY LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
ON OR BEFORE THE ENTRY OF THE STIPULATION AND CONSENT ORDER, THE COMPANY SHALL IMPLEMENT AND DELIVER TRAINING TO ITS FRAUD TEAM
EMPLOYEES REGARDING THE NOTIFICATIONS REQUIRED BY THE SECURITY BREACH NOTICE ACT. ON OR BEFORE THE ENTRY OF THE STIPULATION AND
CONSENT ORDER, THE COMPANY SHALL UPDATE ITS INTERNAL POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE NOTICE DEADLINES
CONTAINED IN THE SECURITY BREACH NOTICE ACT.

3. Date Initiated (MM/DD/YYYY):

08/05/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
24-012-I

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE, INSURANCE, MUTUAL FUND(S)

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
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. § 2435(B)(3) FOR FAILURE TO NOTIFY
THE DEPARTMENT OF A DATA BREACH FOR A VERMONT CONSUMER WITHIN 14 DAYS OF THE DATE THE NOTICE TO CONSUMERS, WHICHEVER IS
EARLIER.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

08/05/2024 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 16,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
ON OR BEFORE THE ENTRY OF THE STIPULATION AND CONSENT ORDER, THE COMPANY SHALL IMPLEMENT AND DELIVER TRAINING TO ITS FRAUD
TEAM EMPLOYEES REGARDING THE NOTIFICATIONS REQUIRED BY THE SECURITY BREACH NOTICE ACT. ON OR BEFORE THE ENTRY OF THE
STIPULATION AND CONSENT ORDER, THE COMPANY SHALL UPDATE ITS INTERNAL POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH
THE NOTICE DEADLINES CONTAINED IN THE SECURITY BREACH NOTICE ACT.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $16,000 PAID ON SEPTEMBER 5, 2024. THE FULL AMOUNT WAS LEVIED AGAINST THE VARIABLE ANNUITY LIFE INSURANCE
COMPANY WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
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. § 2435(B)(3) FOR FAILURE TO NOTIFY
THE DEPARTMENT OF A DATA BREACH FOR A VERMONT CONSUMER WITHIN 14 DAYS OF THE DATE THE NOTICE TO CONSUMERS, WHICHEVER IS
EARLIER.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

No Information Filed

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FLORIDA OFFICE OF INSURANCE REGULATION

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

11/26/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
400070-24-CO

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE INSURANCE OTHER - LIFE AND HEALTH

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DECEMBER 17, 2024, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000
IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF
627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT
DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL
1, 2024. THE CONSENT ORDER WAS EXECUTED ON DECEMBER 18, 2024.
8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

12/18/2024 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 13,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON DECEMBER 17, 2024, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000
IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF
627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT
DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL
1, 2024. THE CONSENT ORDER WAS EXECUTED ON DECEMBER 18, 2024.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
MARYLAND INSURANCE ADMINISTRATION

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
REMEDIATION OF EXCEPTIONS FOUND AND A REPORT TO THE DEPARTMENT WITHIN 90 DAYS OF THE CONSENT ORDER INDICATING COMPLIANCE, WITH
THE EXCEPTION OF FINDING 4, FOR WHICH THE COMPANY WILL SUBMIT A REMEDIATION PROGRESS REPORT WITHIN 45 DAYS OF THE ORDER AND
EVERY 30 DAYS THEREAFTER UNTIL A ROLLING PRODUCTION SCHEDULE IS ESTABLISHED. AT THAT TIME, QUARTERLY REPORTS WILL BE SUBMITTED
UNTIL REMEDIATION OF THAT FINDING IS COMPLETED, AT A DATE NO LATER THAN AUGUST 31, 2022.

3. Date Initiated (MM/DD/YYYY):

03/09/2020 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
NO. MIA-2021-09-023

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN SEPTEMBER 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.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

09/30/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 32,250.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
REMEDIATION OF EXCEPTIONS FOUND AND A REPORT TO THE DEPARTMENT WITHIN 90 DAYS OF THE CONSENT ORDER INDICATING COMPLIANCE,
WITH THE EXCEPTION OF FINDING 4, FOR WHICH THE COMPANY WILL SUBMIT A REMEDIATION PROGRESS REPORT WITHIN 45 DAYS OF THE
ORDER AND EVERY 30 DAYS THEREAFTER UNTIL A ROLLING PRODUCTION SCHEDULE IS ESTABLISHED. AT THAT TIME, QUARTERLY REPORTS WILL
BE SUBMITTED UNTIL REMEDIATION OF THAT FINDING IS COMPLETED, AT A DATE NO LATER THAN AUGUST 31, 2022.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $32,250.00 PAID ON 09/23/2021. THE FULL FINE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE
COMPANY WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SEPTEMBER 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 TIMEPERIOD OF JUNE 1, 2018 THROUGH JANUARY 31, 2020.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/06/2021 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
MIA-2021-11-014

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $1,500.00 ADMINISTRATIVE FINE TO THE MARYLAND INSURANCE
ADMINISTRATION AS THE RESULT OF A REGULATORY COMPLAINT, BASED ON THEADMINISTRATION'S FINDING THAT THE COMPANY ALLEGEDLY
COLLECTED BOTH PREMIUMS AND POLICY DIVIDENDS ON THE POLICIES OF TWO INSUREDS, AND ALLEGEDLY FAILED TO APPLY THOSE DIVIDENDS TO
PAY THE POLICIES' PREMIUMS, RESULTING IN ONE OF THOSE POLICIES LAPSING.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):

12/18/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 1,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $1,500.00 ADMINISTRATIVE FINE TO THEMARYLAND INSURANCE
ADMINISTRATION AS THE RESULT OF A REGULATORY COMPLAINT, BASED ON THEADMINISTRATION'S FINDING THAT THE COMPANY ALLEGEDLY
COLLECTED BOTH PREMIUMS AND POLICY DIVIDENDS ON THE POLICIES OF TWO INSUREDS, AND ALLEGEDLY FAILED TO APPLY THOSE DIVIDENDS TO
PAY THE POLICIES' PREMIUMS, RESULTING IN ONE OF THOSE POLICIES LAPSING.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NEW HAMPSHIRE INSURANCE DEPARTMENT

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
THE NEW HAMPSHIRE INSURANCE DEPARTMENT REQUIRED A NARRATIVE TO THE NHID DESCRIBING THE TRAINING AND/OR CHANGES TO PROCEDURE
AMERICAN GENERAL LIFE INSURANCE COMPANY HAS IMPLEMENTED TO ENSURE VIOLATION OF NH RSA 400-A:16, II DOES NOT OCCUR GOING
FORWARD.

3. Date Initiated (MM/DD/YYYY):

02/29/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
24-012-EP

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 30, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY OF $2,500.00TO THE NEW HAMPSHIRE
INSURANCE DEPARTMENT TO RESOLVE ALLEGED VIOLATIONS THAT THE COMPANY VIOLATED NHRSA 400-A:16, II BY FAILING TO RESPOND WITHIN 10
WORKING DAYS TO THE NHID'S JANUARY 10, 2024 REQUEST ANDBY FAILING TO RESPOND WITHIN 10 WORKING DAYS TO THE NHID'S JANUARY 30, 2024
REQUEST.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

04/03/2024 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 2,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
THE NEW HAMPSHIRE INSURANCE DEPARTMENT REQUIRED A NARRATIVE TO THE NHID DESCRIBING THE TRAINING AND/OR CHANGES TO
PROCEDURE AMERICAN GENERAL LIFE INSURANCE COMPANY HAS IMPLEMENTED TO ENSUREVIOLATION OF NH RSA 400-A:16, II DOES NOT
OCCUR GOING FORWARD
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $2,500 PAID ON MARCH 30, 2024. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE
COMPANY WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MARCH 30, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY OF $2,500.00TO THE NEW HAMPSHIRE
INSURANCE DEPARTMENT TO RESOLVE ALLEGED VIOLATIONS THAT THE COMPANY VIOLATED NHRSA 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.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
MISSOURI DEPARTMENT OF COMMERCE & INSURANCE, DIVISION OF INSURANCE MARKET REGULATION

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/15/2022 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
AGLIC522

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 27, 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $2,000.00 VOLUNTARY FORFEITURE AS ARESULT OF A MARKET CONDUCT
INVESTIGATION. THE DIVISION ALLEGED THAT THE COMPANY 1) FAILED TO RETAIN COPIES OF THE CERTIFICATE APPLICATIONS, GROUP POLICY(IES),
GROUP POLICY FORM NUMBER, EMPLOYER NAME(S), AND RECORD OF TERMINATION DATE(S) OF THE GROUP(S) INFORCE SPECIFIED DISEASE
CERTIFICATES, AND 2)MISREPRESENTED BY OMISSION THE BENEFITS, ADVANTAGES, CONDITIONS, AND TERMS OF THE GROUP POLICY AND SPECIFIED
DISEASE CERTIFICATE WHEN THE COMPANY DID NOT NOTIFY CERTIFICATE HOLDERS OF THE TERMINATION OF COVERAGE AFTER THE GROUP MASTER
POLICY WAS CANCELLED/TERMINATED.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

05/10/2022 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 2,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 27, 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $2,000.00 VOLUNTARY FORFEITURE AS ARESULT OF A MARKET CONDUCT
INVESTIGATION. THE DIVISION ALLEGED THAT THE COMPANY 1) FAILED TO RETAIN COPIES OF THE CERTIFICATE APPLICATIONS, GROUP POLICY(IES),
GROUP POLICY FORM NUMBER, EMPLOYER NAME(S),AND RECORD OF TERMINATION DATE(S) OF THE GROUP(S) INFORCE SPECIFIED DISEASE
CERTIFICATES, AND 2)MISREPRESENTED BY OMISSION THE BENEFITS, ADVANTAGES, CONDITIONS, AND TERMS OF THE GROUP POLICY AND SPECIFIED
DISEASE CERTIFICATE WHEN THE COMPANY DID NOT NOTIFY CERTIFICATE HOLDERS OF THE TERMINATION OF COVERAGE AFTER THE GROUP MASTER
POLICY WAS CANCELLED/TERMINATED. THE COMPANY AGREED TO THE FOLLOWING REMEDIAL ACTION: FILE AN AMENDMENT TO THE GROUP
CERTIFICATE STATING AMERICAN GENERAL WILL NOT CANCEL THE CERTIFICATES OR MAKE COVERAGE DETERMINATIONS EXCEPT BASED ON
PROVISIONS IN THE CERTIFICATE; PROVIDE THE 10 INFORCE CERTIFICATE HOLDERS THE OPTION TO CONTINUE COVERAGE OR BE ISSUED A REFUND
BACK TO DECEMBER 31, 2012, LESS BENEFITS RECEIVED; AND MAINTAIN BUSINESS RECORDS IN ACCORDANCE WITH APPLICABLE LAW.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
INSURANCE DEPARTMENT OF THE COMMONWEALTH OF PENNSYLVANIA

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
REMEDIATION OF EXCEPTIONS FOUND, AND THE DEPARTMENT MAY INQUIRE ABOUT THE COMPANY'S IMPLEMENTATION OF THE RECOMMENDATION NO
EARLIER THAN 12 MONTHS FROM THE DATE OF THE ORDER.

3. Date Initiated (MM/DD/YYYY):

01/10/2022 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
MC23-06-001

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE INSURANCE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON AUGUST 3, 2023, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $160,000 VOLUNTARY FORFEITURE TO THE INSURANCE DEPARTMENT OF
THE COMMONWEALTH OF PENNSYLVANIA TO RESOLVE ALLEGED VIOLATIONS ARISING OUTOF THE STATE'S MARKET CONDUCT EXAMINATION OF THE
COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY, AND GROUP ANNUITY BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2021 THROUGH
DECEMBER 31, 2021.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

07/10/2023 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 160,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
REMEDIATION OF EXCEPTIONS FOUND, AND THE DEPARTMENT MAY INQUIRE ABOUT THE COMPANY'S IMPLEMENTATION OF THE
RECOMMENDATION NO EARLIER THAN 12 MONTHS FROM THE DATE OF THE ORDER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $160,000 PAID ON AUGUST 3, 2023. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE
COMPANY WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON AUGUST 3, 2023, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $160,000 VOLUNTARY FORFEITURE TO THE INSURANCE DEPARTMENT OF
THE COMMONWEALTH OF PENNSYLVANIA TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE
COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY, AND GROUP ANNUITY BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2021 THROUGH
DECEMBER 31, 2021.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
KENTUCKY DEPARTMENT OF INSURANCE

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

12/11/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2024JRT260 AND 2024JRT235

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO PROVIDE COMPLETE AND TIMELY RESPONSES TO THE DEPARTMENT.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):

02/11/2025 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 6,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
THE COMPANY SUBMITTED AN EXPLANATION LETTER AND PAID THE CIVIL PENALTIES TOTALING $6000.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
CIVIL PENALTY OF $6,000

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UTAH INSURANCE DEPARTMENT

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/13/2025 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2025-4751

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:
LIFE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 23, 2025, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID $160,500 VOLUNTARY FORFEITURE TO THE UTAH INSURANCE DEPARTMENT
TO RESOLVE THE DEPARTMENT'S FINDING THAT THE COMPANY WAS LIABLE FOR VIOLATIONS CONDUCTED BY AN APPOINTED AGENT UNDER UTAH CODE
31A-23A-405(2).

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

03/27/2025 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 160,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 23, 2025, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID $160,500 VOLUNTARY FORFEITURE TO THE UTAH INSURANCE DEPARTMENT
TO RESOLVE THE DEPARTMENT'S FINDING THAT THE COMPANY WAS LIABLE FOR VIOLATIONS CONDUCTED BY AN APPOINTED AGENT UNDER UTAH CODE
31A-23A-405(2).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):

06/01/2020 Exact Explanation
If not exact, provide explanation:
ESTIMATED DATE THE AMERICAN GENERAL LIFE INSURANCE COMPANY RECEIVED A SURVEY NOTICE FROM THE COMMISSIONER'S OFFICE TO VERIFY
PRODUCER COMPLIANCE WITH ANNUITY SUITABILITY TRAINING REQUIREMENTS.

4. Docket/Case Number:
ORDER NO. 21-0649

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $10,000.00 ADMINISTRATIVE FINE TO THE OFFICE OF THE INSURANCE
COMMISSIONER FOR THE STATE OF WASHINGTON BASED ON THE COMMISSIONER'S FINDING THAT THE COMPANY ALLEGEDLY ACCEPTED
APPLICATIONS IN 2019 AND 2020 FROM PRODUCERS WHO DID NOT COMPLETE THE STATE'S REQUIRED ANNUITY SUITABILITY TRAINING.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

11/24/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $10,000.00 ADMINISTRATIVE FINE TO THE OFFICE OF THE INSURANCE
COMMISSIONER FOR THE STATE OF WASHINGTON BASED ON THE COMMISSIONER'S FINDING THAT THE COMPANY ALLEGEDLY ACCEPTED
APPLICATIONS IN 2019 AND 2020 FROM PRODUCERS WHO DID NOT COMPLETE THE STATE'S REQUIRED ANNUITY SUITABILITY TRAINING.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
DELAWARE DEPARTMENT OF INSURANCE

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
REMEDIATION OF EXCEPTIONS FOUND AND A REPORT WITHIN 30 DAYS OF THE CONSENT ORDER INDICATINGCOMPLIANCE. FAILURE TO REPORT OR TO
COMPLY COULD RESULT IN ADDITIONAL MONETARY PENALTIES, PROHIBITIONOF NEW BUSINESS IN THE STATE, AND/OR SUSPENSION OR REVOCATION
OF THE COMPANY'S CERTIFICATE OFAUTHORITY.

3. Date Initiated (MM/DD/YYYY):

06/30/2020 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
4516

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN AUGUST 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $106,000.00 ADMINISTRATIVE FINE TO THEDELAWARE DEPARTMENT OF
INSURANCE TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINEMARKET CONDUCT EXAMINATION OF THE COMPANY'S
INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY BUSINESSES.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

08/12/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 106,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
REMEDIATION OF EXCEPTIONS FOUND AND A REPORT WITHIN 30 DAYS OF THE CONSENT ORDER INDICATING COMPLIANCE. FAILURE TO REPORT
OR TO COMPLY COULD RESULT IN ADDITIONAL MONETARY PENALTIES,PROHIBITION OF NEW BUSINESS IN THE STATE, AND/OR SUSPENSION OR
REVOCATION OF THE COMPANY'S CERTIFICATE OF AUTHORITY.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $106,000.00 PAID ON 8/11/2021. FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY
WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN AUGUST 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $106,000.00 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 BUSINESSES.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
AMERICAN GENERAL LIFE INSURANCE COMPANY ("AGL") SHALL SUBMIT TO NYSDFS, ANNUAL AFFIDAVITS OF COMPLIANCE WITH THE TERMS OF THE
CONSENT ORDER FOR A PERIOD OF 3 YEARS COMMENCING FROM THE EFFECTIVE DATE OF THE CONSENT ORDER.

3. Date Initiated (MM/DD/YYYY):

01/28/2021 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
N/A

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6. Principal Product Type:
Insurance
Other Product Types:
PENSION RISK TRANSFER

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
AMERICAN INTERNATIONAL GROUP, INC. ("AIG") AND AGL ENTERED INTO A CONSENT ORDER WITH NYSDFS FINDINGTHAT AGL HAD CONDUCTED AN
INSURANCE BUSINESS IN NEW YORK WITHOUT A NEW YORK LICENSE IN CONNECTIONWITH ITS PENSION RISK TRANSFER ("PRT") BUSINESS, IN
VIOLATION OF INSURANCE LAW § 1102(A).

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

01/28/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 12,000,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
PURSUANT TO THE ORDER, AGL WILL ALSO TAKE AGREED-UPON ACTIONS WITH RESPECT TO NY-BASEDPARTICIPANTS IN LEGACY AND FUTURE
PRT TRANSACTIONS TO ENSURE ACTIVITIES IN NY ARE APPROPRIATELYLICENSED AND IN COMPLIANCE WITH NY LAW. AGL MUST SUBMIT ANNUAL
AFFIDAVITS OF COMPLIANCE WITH THETERMS OF THE ORDER FOR A PERIOD OF 3 YEARS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
PURSUANT TO THE ORDER, AGL WILL ALSO TAKE AGREED-UPON ACTIONS WITH RESPECT TO NY-BASEDPARTICIPANTS IN LEGACY AND FUTURE
PRT TRANSACTIONS TO ENSURE ACTIVITIES IN NY ARE APPROPRIATELYLICENSED AND IN COMPLIANCE WITH NY LAW. AGL MUST SUBMIT ANNUAL
AFFIDAVITS OF COMPLIANCE WITH THETERMS OF THE ORDER FOR A PERIOD OF 3 YEARS. AGL PAID THE $12,000,000 CIVIL PENALTY ON
02/05/2021.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

06/25/2018 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
MARKET CONDUCT EXAMINATION NO. 317030

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Insurance
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN JUNE 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $117,300.00 VOLUNTARY FORFEITURE TO THE MISSOURI STATE SCHOOL FUND
TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S LIFE AND ACCIDENT & HEALTH
BUSINESS, COVERING THE TIME PERIOD JANUARY 1,2014 THROUGH DECEMBER 31, 2017.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

06/10/2022 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 117,300.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
REMEDIATION OF EXCEPTIONS FOUND, AND A REPORT TO THE DEPARTMENT WITHIN 90 DAYS OF THE CONSENTORDER INDICATING COMPLIANCE
WITH ITEMS IN REMEDIAL ACTION SECTION OF THE ORDER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL AMOUNT PAID: $117,300.00 PAID ON 6/3/2022. THE FULL FORFEITURE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE
INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN JUNE 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $117,300.00 VOLUNTARY FORFEITURE TO THE MISSOURI STATE SCHOOL FUND
TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S LIFE AND ACCIDENT & HEALTH
BUSINESS, COVERING THE TIME PERIOD JANUARY 1,2014 THROUGH DECEMBER 31, 2017.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

09/09/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
400072-24-CO

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES)-VARIABLE; INSURANCE; OTHER - LIFE AND HEALTH

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON OCTOBER 2, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN
ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF
627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT
DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL
1, 2024.

8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

10/07/2024 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 13,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OCTOBER 2, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN
ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THEDEPARTMENT'S FINDING OF A VIOLATION OF
627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT
DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL
1, 2024.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

No Information Filed

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
ILLINOIS DEPARTMENT OF INSURANCE

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/02/2025 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE INSURANCE LIFE INSURANCE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JULY 25, 2025, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY AND AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A COMBINED
VOLUNTARY FORFEITURE OF $5,750.00 TO THE ILLINOIS DEPARTMENT OF INSURANCE, $151.32 FOR THE VARIABLE ANNUITY LIFE INSURANCE
COMPANY AND $5,598.68 FOR AMERICAN GENERAL LIFE INSURANCE COMPANY. THE VOLUNTARY FORFEITURE WAS PAID TO RESOLVE ALLEGED
VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANIES' INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY
BUSINESSES COVERING THE 2022 CALENDAR YEAR TIME PERIOD.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

07/14/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 5,750.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 25, 2025, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY AND AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A COMBINED
VOLUNTARY FORFEITURE OF $5,750.00 TO THE ILLINOIS DEPARTMENT OF INSURANCE, $151.32 FOR THE VARIABLE ANNUITY LIFE INSURANCE
COMPANY AND $5,598.68 FOR AMERICAN GENERAL LIFE INSURANCE COMPANY. THE VOLUNTARY FORFEITURE WAS PAID TO RESOLVE ALLEGED
VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANIES' INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY
BUSINESSES COVERING THE 2022 CALENDAR YEAR TIME PERIOD. IN ADDITION, THE VARIABLE ANNUITY LIFE INSURANCE COMPANY IS ORDERED BY
THE ILLINOIS DEPARTMENT OF INSURANCE TO REMEDIATE ONE FINDING AND TO SUBMIT PROOF OF COMPLIANCE TO THE DEPARTMENT BY AUGUST 15,
2025.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/02/2025 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
ANNUITY(IES) - VARIABLE INSURANCE LIFE INSURANCE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JULY 25, 2025, AMERICAN GENERAL LIFE INSURANCE COMPANY AND THE VARIABLE ANNUITY LIFE INSURANCE COMPANY PAID A COMBINED
VOLUNTARY FORFEITURE OF $5,750.00 TO THE ILLINOIS DEPARTMENT OF INSURANCE, $5,598.68 FOR AMERICAN GENERAL LIFE INSURANCE COMPANY
AND $151.32 FOR THE VARIABLE ANNUITY LIFE INSURANCE COMPANY. THE VOLUNTARY FORFEITURE WAS PAID TO RESOLVE ALLEGED VIOLATIONS
ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANIES' INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY BUSINESSES
COVERING THE 2022 CALENDAR YEAR TIME PERIOD.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

07/14/2025 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 5,750.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 25, 2025, AMERICAN GENERAL LIFE INSURANCE COMPANY AND THE VARIABLE ANNUITY LIFE INSURANCE COMPANY PAID A COMBINED
VOLUNTARY FORFEITURE OF $5,750.00 TO THE ILLINOIS DEPARTMENT OF INSURANCE, $5,598.68 FOR AMERICAN GENERAL LIFE INSURANCE COMPANY
AND $151.32 FOR THE VARIABLE ANNUITY LIFE INSURANCE COMPANY. THE VOLUNTARY FORFEITURE WAS PAID TO RESOLVE ALLEGED VIOLATIONS
ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANIES' INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY BUSINESSES
COVERING THE 2022 CALENDAR YEAR TIME PERIOD. IN ADDITION, AMERICAN GENERAL LIFE INSURANCE COMPANY IS ORDERED BY THE ILLINOIS
DEPARTMENT OF INSURANCE TO REMEDIATE THREE FINDINGS AND TO SUBMIT PROOF OF COMPLIANCE TO THE DEPARTMENT BY AUGUST 15, 2025.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: AMERICAN GENERAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

06/12/2026 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2026-IN-010

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
INSURANCE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION DETERMINED THAT THE COMPANY'S INTERNAL REPLACEMENT DISCLOSURE FORM DID NOT COMPLY WITH THE REQUIREMENTS OF R.I.
GEN. LAWS 27-29-4.7.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

06/12/2026 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
TOTAL ADMINISTRATIVE PENALTY PAID IN THE AMOUNT OF $10,000 ON JUNE 17, 2026.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JUNE 12, 2026, AMERICAN GENERAL LIFE INSURANCE COMPANY SIGNED A CONSENT AGREEMENT ARISING FROM AN ANALYSIS WHEREBY THE
DIVISION DETERMINED THAT THE COMPANY'S INTERNAL REPLACEMENT DISCLOSURE FORM DID NOT COMPLY WITH THE REQUIREMENTS OF R.I. GEN.
LAWS 27-29-4.7. THE COMPANY AGREED TO AND PAID A $10,000 ADMINISTRATIVE PENALTY.

CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)

No Information Filed

Part 2
Exemption from brochure delivery requirements for SEC-registered advisers

SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a
brochure to all of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules?

If no, complete the ADV Part 2 filing below.

Amend, retire or file new brochures:

Part 3

CRS Type(s) Affiliate Info Retire

There are no CRS filings to display.

Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.

Appointment of Agent for Service of Process

By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the
state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to
receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand
for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state
action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or
arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b)
is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939,
the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state
in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.

Signature

I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.

I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.

Signature: Date: MM/DD/YYYY
MELISSA ROBINS 07/09/2026
Printed Name: Title:
MELISSA ROBINS INVESTMENT ADVISER CHIEF COMPLIANCE OFFICER
Adviser CRD Number:
104561

NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.

1. Appointment of Agent for Service of Process

By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or
other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such
persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or
papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or
arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any
activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly,
upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a
notice filing.

2. Appointment and Consent: Effect on Partnerships

If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws
from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this
irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.

3. Non-Resident Investment Adviser Undertaking Regarding Books and Records

By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in
Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission,
correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940.
This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of
attorney or any of your general partners and managing agents.

Signature

I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both
certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits
and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.

Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
104561