Business Continuity

Business Continuity Statement

The scope of AIG Retirement Advisors, Inc.’s (ARA) business continuity planning today entails certain key ARA business operations and data center locations. Business continuity planning is the process which defines the procedures employed to ensure the timely and orderly resumption of a company’s business, through its ability to execute plans with minimal or no interruption to time-sensitive business operations. Specific plans have been developed and teams have been identified for each time-sensitive business operation. Each plan prioritizes the critical business functions and states a strategy for recovery within a specified timeframe. ARA’s ultimate parent company, the American International Group, Inc. (AIG) maintains the AIG Business Continuity Planning Department which has primary responsibility for the guidelines, methodologies, and the framework to support the strategies for recovery for all subsidiary companies including ARA. The AIG Business Continuity Planning infrastructure is responsible for developing and maintaining the plans.

ARA Business Continuity Planning Objectives

The objectives of the ARA Business Recovery Continuity Plan are to:

• Avoid or minimize deaths and injuries.

• Control and terminate incidents as quickly as possible.

• Prevent a minor incident from becoming a major disaster.

• Minimize commercial and reputation damage.

• Protect ARA assets and financial position.

• Minimize the risk of legal liabilities.

• Resume and recover any disrupted business function or operation rapidly and effectively.

• Ensure compliance with all applicable laws and regulations.

• Maintain the confidence and good relations with public safety and regulatory agencies customers, service providers, and other official parties.

• Satisfy the interests and concerns of ARA programs and other related business entities.

ARA Business Continuity Guidelines

The ARA Business Continuity Plans were developed in accordance with established methodology defined by AIG following Business Continuity Planning best practices. Each business unit followed documented enterprise-wide guidelines for contingency planning and disaster recovery for risk assessment, business impact analysis, business contingency plan, and plan testing.

• Risk Assessment – There are numerous risks to any business. From natural to man-made these risks can be, or may become, threats to ARA’s business. ARA threats with the greatest probability include storms or hurricanes, high water or flooding, fire, bomb threats, terrorist attacks, breach of security and general service interruption. A risk assessment was performed by ARA Facilities/Property Management for each ARA facility. Each business unit then assessed any additional risks that would pertain to that unit’s specific operation.

• Business Impact Analysis – Each ARA business unit is required to identify the time criticality of each business function, as well as the resources that the function needs to successfully recover. Additionally, each unit must review annually the time criticality of all business functions.

• Business Contingency Plan – ARA business units document and update annually a contingency plan to support the business unit’s needs. Contingency plans include event management procedures, employee communication strategies, alternate site requirements, and procedures for notification to clients, recovery management, and alternate site preparation checklists.

• Plan Testing – Once the recovery plan documentation is complete, it is tested regularly to ensure that recovery capability remains viable. At least one full-scale recovery simulation, or a series of logically organized, segmented exercises representing a full exercise, is conducted annually. In addition to full-scale recovery simulation tests, an annual tabletop/walkthrough exercise of the plan is conducted to gauge each participant’s understanding of individual roles and responsibilities.

ARA Recovery Strategies

Threats that materialize can cause varying degrees of outages that can be classified as short-term, intermediate-term, or long-term. Day-to-day emergencies are addressed at ARA through emergency response/escalation procedures that are used when needed. ARA Business Continuity Plans have been developed to address a variety of disaster categories. The categories are defined as follows:

• Short-Term: Workplace Damaged or Inaccessible

• Intermediate Term: Building Damaged or Campus Inaccessible

• Long-Term: Worst Case Scenario (Local or Citywide Evacuation)

ARA Disaster Recovery

AIG currently contracts with a third party vendor for recovery services. This third party vendor provides a recovery location for the Houston campus and many of the remote ARA branch offices. AIG also contracts for mainframe operations, which includes a recovery option for mainframe restoration. In the event of a disaster, ARA’s third party vendor will restore the mainframe at a SunGard remote facility. Once the mainframe is restored, business units will be able to access mainframe applications through a designated Disaster Recovery circuit. All business units currently accessing the mainframe through our local network will be able to access the mainframe during a disaster situation. When the AIG Houston main campus declares a disaster, the Technical Recovery Teams immediately send the required personnel and all back up tapes to the designated vendor recovery center to restore open systems. The Technical Recovery Team restores the infrastructure that allows for the recovery and restoration of critical business databases and applications to the most current recovery point as dictated by business requirements. Business users will be relocated to the end user recovery site or another appropriate location. Operations using Open Systems will continue at the hot site for 6 weeks or until the damaged facility is repaired or a suitable alternate facility is acquired. In the event ARA ceases operations, customers can call the customer service line at 800-572-1980

ARA and its clearing firm, National Financial Services, LLC, (NFS), have an agreement in which NFS may provide trade execution, clearing, and other related services for your brokerage account. NFS backs up ARA’s important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, ARA has been advised by NFS that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments in a timely manner. Your orders and requests for funds and securities could be delayed during this period.

AIG Retirement Advisors, Inc. Member of FINRA, SIPC

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To help the government fight the funding of terrorism and money-laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who purchases certain annuity products. What this means for you: When you purchase certain annuity products from us, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may ask to see your driver's license or other identifying documents.

Annuities and insurance products are offered by The Variable Annuity Life Insurance Company (VALIC), AIG Annuity Insurance Company, AIG-affiliated insurance companies or other approved companies. Each underwriting company is financially responsible for its own insurance products.

Securities and investment advisory services are offered by AIG Retirement Advisors, Inc., member FINRA, SIPC and an SEC-registered investment advisor.

AIG Retirement is the marketing name for the group of companies comprising AIG Retirement Advisors, Inc.; AIG Retirement Services Company; and The Variable Annuity Life Insurance Company (VALIC); each of which is a subsidiary of American International Group, Inc.

This information is general in nature and may be subject to change. Neither VALIC nor its financial advisors or other representatives give legal or tax advice. Applicable laws and regulations are complex and subject to change. For legal or tax advice concerning your situation, consult your attorney or professional tax advisor.