X0405TA-1/A0001202048XXXXXXXX084-06057trueLIVESECVALIC RETIREMENT SERVICES COAIG RETIREMENT SERVICES CO5025752919 Allen ParkwayHoustonTX77019N713-831-3150NNNNCorporationMark Matthes03/16/2012Vice PresidentNA11/22/2019The Variable Annuity Life Insurance Company (VALIC)11/18/1996OwnerEtrueCynthia Burnette07/13/2017Vice President and Assistant TreasurerNAJennifer Martin09/03/2019Director, VPA TradingNAJin Han09/03/2019Manager, VPA TradingNAYThe Variable Annuity Life Insurance Company, AGC Life Insurance Company, AIG Life Holdings, Inc., SAFG Retirement Services, and American Intl Group.The VALIC Retirement Services Company is 100 owned by The Variable Annuity Life Insurance Company. The Variable Annuity Life Insurance Company is 100 percent owned by AGC Life Insurance Company, which is 100 percent owned by AIG Life Holdings, Inc., which is 100 percent owned by SAFG Retirement Services, Inc. (DE), which is 100 percent by owned American International Group, Inc. (AIG).NNNNNYAmerican International Group, Inc.Injunction02/06/2006Securities and Exchange CommissionTHE SEC COMPLAINT ALLEGED THAT FROM 2000 UNTIL 2005, AIG MATERIALLY FALSIFIED ITS FINANCIAL STATEMENTS IN ORDER TO STRENGTHEN THE APPEARANCE OF ITS FINANCIAL RESULTS TO ANALYSTS AND INVESTORS. IN SO DOING, THE SEC ALLEGED THAT AIG HAD VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933 AND SECTIONS 10(B), 13(A), 13(B)(2) AND 13(B)(5) AND RULES 10B-5, 12B-20, 13A-1, 13A-13 AND 13B2-1 OF THE EXCHANGE ACT OF 1934.Settled 2/17/2006YAmerican International Group, Inc.Docket SDNY - Case No. 06 CIV 100002/09/2006Securities and Exchange CommissionThe SEC Complaint alleged that from 2000 until 2005, AIG materially falsified its financial statements in order to strengthen the appearance of its financial results to analysts and investors. In so doing, the SEC Alleged that AIG had violated Section 17(A) of The Securities Act of 1933 and Sections 10(B), 13(A), 13(B)(2) and 13(B)(5) and Rules 10B-5, 12B-20, 13A-1, 13A-13 and 13B2-1 of the Exchange Act.Settled 2/17/2006NNYThe VARIABLE ANNUITY LIFE INSURANCE COMPANY (VALIC)Docket/Case Number: 08-1728-908/06/2015West Virginia Securities CommissionThe State alleged in twenty-four separate summary orders 1) VALIC acted as an investment adviser without proper registration, 2) advertisement violation, 3) VALIC and its agent defrauded investors by misleading them, misrepresenting material facts, and implying the were representatives of the school board or the State, 4) statements/omissions were misleading and constituted a scheme to defraud WV residents, and 5) failure of VALIC's agent to disclose to his client that was employed and controlled by VALIC.Vacated 5/3/2019.VALIC Financial Advisors, Inc. (VFA)Docket/Case Number: 16-0572-DEN06/14/2016State of Oklahoma Insurance DepartmentDue to an administrative error, VFA omitted certain FINRA regulatory actions on its insurance agency application.VFA agreed to settlement and paid $300 administrative fine.Sean Placido RodriguezFile No. LCB 1159-A11/22/2013California Department of InsuranceFailed to report December 22, 2012, settlement with FINRACalifornia Insurance License revoked/restricted license issued.VALIC Financial Advisors, Inc. (VFA)Docket/Case Number: 16-0572-DEN06/24/2016State of Oklahoma Insurance DepartmentVFA filed an administrative agency application on behalf of VALIC Financial Advisors, Inc., in the the State of Oklahoma. Due to an administrative error, the application omitted certain FINRA Regulatory Actions. VFS amended its application. The State issued an administrative fine against VFA for $300 for omitting the regulatory event in its application.VFA agreed to settlement and paid the $300 administrative fee.VALIC Financial Advisors, Inc. (VFA)Docket/Case Number: 10013034010/07/2016Alaska Division of InsuranceAlaska issued an administrative fine against VFA in the amount of $100 for failing to timely report the fine issued by the State of Oklahoma.VFA settled the matter and paid the fine.VALIC Financial Advisors, Inc. (VFA)Docket/Case Number; 11/7/201611/07/2016Louisiana Department of InsuranceLouisiana issued an administrative fine against VFA for $500 for omitting prior regulatory events in the initial application and failing to timely report the fine issued by the State of Oklahoma.VFA settled the matter and paid the $500 fine.YZachary Ranstead Pittinger (VALIC Financial Advisors, Inc.)Docket/Case Number: IC10-CAF-0101/22/2010Texas State Securities BoardAlleged that investment advisory services were provided without being registerered as an IAR.Reprimand, $4,000 FineWilliam Hilton Burke (VALIC Financial Advisors, Inc.)Docket/Case Number: 0096-SR-7/1008/09/2010Florida Office of Financial RegulationAllegedly conducted investment advisory business without the benefit of lawful registration.Ceast and desist, $2,500 Fine.Sean Placido Rodriguez (VALIC Financial Advisors, Inc.)Case Number 201002380480112/18/2012FINRAAllegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations.AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000VALIC Financial Advisors, Inc.SEU-2018-00105/30/2019Hawaii Department of Commerce and Consumer AffairsHawaii alleged that the firm failed to supervise a registered representative who had submitted a transactions without proper customer authorization.Monetary/Fine $10,000. Cease and Desist/InjunctionYSean Placido Rodriguez (VALIC Financial Advisors, Inc.)Case Number 201002380480112/18/2012FINRAAllegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations.AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000YSean Placido Rodriguez (VALIC Financial Advisors, Inc.)Case Number 201002380480112/18/2012FINRAAllegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations.AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000American General Life Insurance CompanyDocket/Case Number: 10-076-S09/20/2010Vermont Dept of Banking, Insurance, Securities and Healthcare Administration ("BSunAmerica Annuity and Life Assurance Company ("SALAC") merged into American General Life Insurance Company ("AGLIC") in December 2012. AGLIC is a related person of Varagon Capital Partners, L.P. BISHCA alleged that SALAC violated the Vermont Uniform Securities Act by (1) using a prospectus that was ambiguous in describing its automatic asset re-balance program feature applicable to certain variable annuities, and (2) not re-balancing certain sub-accounts within the annuities to return to allocations given in the account owners' last trade instructions.Stipulation and Consent. Sanction ordered in the amount of $100,000.YSean Placido Rodriguez (VALIC Financial Advisors, Inc.)Case Number 201002380480112/18/2012FINRAAllegedly executed or caused to be executed numerous discretionary transactions in a customer's account without authority/unsuitable recommendations.AWC: Suspension (60 days/all capacities), $10,000 fine, Restitution $5,000YRobert Jacob Bourgeois (Varagon Capital Partners, LP)Docket/Case Number: 1205-1016409/12/2012Texas State Board of Public AccountancyLicense may be reinstated upon completion on continuing education requirements and payment of penalty fee.Suspension/Administrative revocation: CPA LicenseYRenee Lynn Coil (VALIC Financial Advisors, Inc)Docket/Case Number: 200801475640107/30/2010FINRAAlleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges.One-month suspensionYAIG Capital Services, Inc.Docket/Case Number: C1100001407/07/2000National Association of Securities Dealers, Inc.The NASD alleged AIG Capital Services, Inc. ("ACS") failed to establish, maintain, and enforce written supervisory procedures reasonably designed to achieve compliance with applicable rules of NASD, to ensure (I) the timely filing and processing of registration applications; (II) the timely filing and processing of notices reporting terminations of employment; and (III) that its registered representatives fulfilled the requirements of the regulatory element of the continuing education program.AWC/Sanctions Ordered: Censure, Monetary Fine $75,000.00.VALIC Financial Advisors, Inc. (VFA)Docket/Case Number: 201404236000111/28/2016FINRAAlleged violations of NASD Rule 3010)(A)(B) and FINRA Rules 2010, 2330( C), (D), and E.AWC: Censure, Monetary Fine $1,750,000Renee Lynn Coil (VALIC Financial Advisors, Inc)Docket/Case Number: 200801475640107/30/2010FINRAAlleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges.One-month suspensionYRenee Lynn Coil (VALIC Financial Advisors, Inc.)Docket/Case Number: 200801475640107/30/2010FINRAAlleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges.One-month suspensionYRenee Lynn Coil (VALIC Financial Advisors, Inc.)Docket/Case Number: 200801475640107/30/2010FINRAAlleged violation of NASD Rules 2110 and 2310. Failed to determine the surrender fees related to variable annuity exchanges she recommended to a customer and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges.One-month suspensionNNNNKara R. Boling713-831-6313Director and President03/31/2020