403(B) THRIFT PLAN OF COMMUNITY INVOLVEMENT PROGRAMS FINANCIAL STATEMENTS. December 31, 2016 and 2015

Transcription

1 403(B) THRIFT PLAN OF COMMUNITY INVOLVEMENT PROGRAMS FINANCIAL STATEMENTS

2 TABLE OF CONTENTS Independent Auditor's Report 1 Page Number FINANCIAL STATEMENTS Statements of Net Assets Available for Benefits Statement 1 4 Statement of Changes in Net Assets Available for Benefits Statement 2 5 Notes to Financial Statements 6 SUPPLEMENTAL SCHEDULES Schedule H, Line 4i - Schedule of Assets (Held at End of Year) Schedule 1 14 Schedule H, Line 4a - Schedule of Delinquent Participant Contributions Schedule 2 16

3 INDEPENDENT AUDITOR'S REPORT Board of Directors and Finance Committee 403(b) Thrift Plan of Community Involvement Programs Minneapolis, Minnesota Report on the Financial Statements We were engaged to audit the accompanying financial statements of 403(b) Thrift Plan of Community Involvement Programs, which comprise the statement of net assets available for benefits as of December 31, 2016, and the related statement of changes in net assets available for benefits for the year then ended, and the related notes to the financial statements. Management s Responsibility for the Financial Statements Management is responsible for the preparation and fair presentation of these financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. Accountant s Responsibility Our responsibility is to express an opinion on these financial statements based on conducting the audit in accordance with auditing standards generally accepted in the United States of America. Because of the matter described in the Basis for Disclaimer of Opinion paragraph, however, we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. Basis for Disclaimer of Opinion As permitted by 29 CFR of the Department of Labor's Rules and Regulations for Reporting and Disclosure under the Employee Retirement Income Security Act of 1974, the Plan Administrator instructed us not to perform, and we did not perform, any auditing procedures with respect to the information summarized in Note 3, which was certified by Mutual of America Life Insurance Company and The Variable Annuity Life Insurance Company, the asset custodians of the Plan, except for comparing the information with the related information included in the financial statements. We have been informed by the Plan Administrator that the asset custodians hold the Plan's investment assets and execute investment transactions. The Plan Administrator 4810 White Bear Parkway, St. Paul, MN,

4 has obtained certifications from the asset custodians as of and for the year ended December 31, 2016, that the information provided to the Plan Administrator by the asset custodians is complete and accurate. Disclaimer of Opinion Because of the significance of the matter described in the Basis for Disclaimer of Opinion paragraph, we have not been able to obtain sufficient, appropriate audit evidence to provide a basis for an audit opinion. Accordingly, we do not express an opinion on the financial statements referred to in the first paragraph. Other Matter - Supplemental Schedules The supplemental schedules, Schedule 1 and 2, as of and for the year ended December 31, 2016, are required by the Department of Labor's Rules and Regulations for Reporting and Disclosure under the Employee Retirement Income Security Act of 1974 and are presented for the purpose of additional analysis and are not a required part of the financial statements. Because of the significance of the matter described in the Basis for Disclaimer of Opinion paragraph, we do not express an opinion on the supplemental schedules referred to above. Other Matter 2015 Financial Statements The financial statements of the Plan as of December 31, 2015, were audited by predecessor auditors. As permitted by 29 CFR of the Department of Labor s Rules and Regulations for Reporting and Disclosure under the Employee Retirement Income Security Act of 1974 (ERISA), the Plan administrator instructed the predecessor auditors not to perform, and they did not perform, any auditing procedures with respect to the information certified by Mutual of America Life Insurance Company and The Variable Annuity Life Insurance Company, the asset custodians of the Plan. Their report, dated September 19, 2016, indicated that (a) because of the significance of the information that they did not audit, they were unable to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion and accordingly, they did not express an opinion on the financial statements and (b) the form and content of the information included in the financial statements other than that derived from the information certified by the asset custodians, were presented in compliance with the Department of Labor s Rules and Regulations for Reporting and Disclosure under ERISA 2

5 Report on Form and Content in Compliance With DOL Rules and Regulations The form and content of the information included in the 2016 financial statements and supplemental schedules, other than that derived from the information certified by the asset custodians, have been audited by us in accordance with auditing standards generally accepted in the United States of America and, in our opinion, are presented in compliance with the Department of Labor's Rules and Regulations for Reporting and Disclosure under the Employee Retirement Income Security Act of REDPATH AND COMPANY, LTD. St. Paul, Minnesota July 27,

6 Statement 1 STATEMENTS OF NET ASSETS AVAILABLE FOR BENEFITS Assets: Investments at fair value $4,825,841 $4,243,311 Receivables: Employer contributions receivable 4,331 4,291 Employee contributions receivable 11,908 11,612 Other employer contributions receivable 55,414 - Total assets 4,897,494 4,259,214 Liabilities: Excess contributions payable - 2,541 Net assets available for benefits $4,897,494 $4,256,673 The accompanying notes are an integral part of these financial statements. 4

7 STATEMENT OF CHANGES IN NET ASSETS AVAILABLE FOR BENEFITS Statement 2 For The Year Ended December 31, Additions: Employer contributions $111,436 Employee contributions 262,385 Rollover contributions 337,328 Other employer contributions 55,414 Investment income: Net appreciation in fair value of investments 327,289 Interest and dividends 14,066 Total additions 1,107,918 Deductions: Benefits paid to participants 465,919 Administrative expenses 1,178 Total deductions 467,097 Net increase in net assets available for benefits 640,821 Beginning net assets available for benefits 4,256,673 Ending net assets available for benefits $4,897,494 The accompanying notes are an integral part of these financial statements. 5

8 NOTES TO FINANCIAL STATEMENTS Note 1 DESCRIPTION OF PLAN The following description of the 403(b) Thrift Plan of Community Involvement Programs (the Plan) provides only general information. Participants should refer to the Plan Agreement for a complete description of the Plan's provisions. GENERAL The Plan is a single employer 403(b) defined contribution plan covering substantially all full-time employees of Community Involvement Programs, Inc. (the Employer). Employees who are not highly compensated, not covered under a collective bargaining agreement, have attained age 18 and have completed one year of service are eligible to receive employer matching contributions. There are no excluded employees or minimum age or service requirements for elective salary deferrals. The Plan is subject to the provisions of ERISA and all requirements of Section 403(b) and 403(k) of the Internal Revenue Code (IRC). The Board of Trustees is responsible for oversight of the Plan. The Finance Committee determines the appropriateness of the Plan s investment offerings, monitors investment performance and reports to the Plan s Board of Directors. CONTRIBUTIONS Each year, participants may contribute up to 100 percent of pretax annual compensation, as defined in the Plan. Participants who have attained age 50 before the end of the Plan year are eligible to make catch-up contributions. Participants may also contribute amounts representing distributions from other qualified defined benefit or defined contribution plans (rollover). Participants direct the investment of their contributions into various investment options offered by the Plan. The Employer contributes 100 percent of the first 3 percent of base compensation that a participant contributes to the Plan. The Employer matching contribution is invested as directed by the participant. Contributions are subject to applicable Internal Revenue Service (IRS) limitations. PARTICIPANT ACCOUNTS Each participant's account is credited with the participant's contributions and the Employer s matching contributions, as well as allocations of Plan earnings. Participant accounts are charged with an allocation of administrative expenses that are paid by the Plan. Allocations are based on participant earnings, account balances, or specific participant transactions, as defined. The benefit to which a participant is entitled is the benefit that can be provided from the participant s vested account. VESTING Participants are vested immediately in their contributions plus actual earnings thereon. Participants are also vested immediately in Employer matching contributions plus actual earnings thereon. POLICY LOANS Participants may borrow funds from Mutual of America Life Insurance Company (MOALIC) and The Variable Annuity Life Insurance Company (VALIC) using a portion of their Plan account as security for the policy loan. The minimum loan is $1,000 and may be up to the lesser of $50,000 or 50 percent of their account balance. The loans bear interest at market rates. At December 31, 2016, interest rates ranged from 3.75 percent to 5.50 percent. Principal and interest is paid ratably through periodic direct payments by the participant to MOALIC and VALIC. The Plan Administrator has concluded that these loans are not Plan assets and that such arrangements are exempt transactions. The balances as of were $125,140 and 6

9 NOTES TO FINANCIAL STATEMENTS $135,329, respectively, and are included in the general accounts. Under the borrowing terms, $134,650 and $143,514 of Plan assets serve as collateral to these loans as of, respectively. In the event of default, such loans are reportable to Plan participants as taxable income but remain outstanding and continue to accrue interest until repaid by the Plan participant or the participant becomes eligible to receive a distribution under the terms of the Plan. When a policy loan is deemed to be in default, the participant is issued a 1099-R for the amount of the defaulted loan. No loans went into default during As of December 31, 2016 and 2015, loans in default amounted to $67,383 and $73,438, respectively. Such amounts includes the principal and accumulated interest. PAYMENT OF BENEFITS On termination of service due to death, disability, or retirement, a participant may elect to receive either a lumpsum amount equal to the value of the participant s vested interest in his or her account, or annual installments as defined in the Plan agreement. For termination of service for other reasons, a participant may receive the value of the vested interest in his or her account as a lump sum distribution. The Plan allows for in-service distributions upon attainment of age 59½ and hardship distributions subject to Plan provisions. Note 2 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES BASIS OF ACCOUNTING The financial statements of the Plan are prepared using the accrual basis of accounting. USE OF ESTIMATES The preparation of financial statements in accordance with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and changes in those assets and liabilities, and disclosure of contingent assets and liabilities. Actual results could differ from those estimates. INVESTMENT VALUATION AND INCOME RECOGNITION Investments are reported at fair value. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. The Plan s investment committee determines the Plan s valuation policies utilizing information provided by the investment advisers, custodians and insurance company. See Note 4 for discussion of fair value measurements. Purchases and sales of securities are recorded on a trade-date basis. Interest income is recorded on the accrual basis. Dividends are recorded on the ex-dividend date. Net appreciation includes the Plan s gains and losses on investments purchased and sold as well as held during the year. POLICY LOANS Policy loans between participants and MOALIC are collateralized at 120 percent of the original principal balance of the loan. This policy loan collateral is restricted within the participant s investment in MOALIC s general accounts. Policy loans between participants and VALIC are collateralized at 100 percent of the original principal balance of the loan plus first quarter interest and potential surrender charges. This policy loan collateral is transferred 7

10 NOTES TO FINANCIAL STATEMENTS from a participant s investment in VALIC s general accounts to a loan collateral and escrow account, which bear interest at a contractually guaranteed minimum rate similar to the rate earned on the general accounts. EXCESS CONTRIBUTIONS PAYABLE Amounts payable to participants for contributions in excess of amounts allowed by the IRS are recorded as a liability with a corresponding reduction to contributions. PAYMENT OF BENEFITS Benefits are recorded when paid. EXPENSES Certain expenses of maintaining the Plan are paid by the Plan, unless otherwise paid by the Employer. Expenses that are paid by the Employer are excluded from these financial statements. Investment related expenses are included in net appreciation of fair value investments. RECENT ACCOUNTING PRONOUNCEMENTS In May 2015, the Financial Accounting Standards Board ("FASB") issued Accounting Standards Update (ASU) , Disclosures for Investments in Certain Entities that Calculate Net Asset Value per Share (or its Equivalent). ASU removes the requirement to categorize within the fair value hierarchy all investments for which fair values are estimated using the net asset value as a practical expedient provided by Accounting Standards Codification 820, Fair Value Measurement. Disclosures about investments in certain entities that calculate net asset value per share are limited under ASU to those investments for which the entity has elected to estimate the fair value using the net asset value as a practical expedient. The amendment in ASU is effective for reporting periods beginning after December 15, 2016, with early adoption permitted. Effective January 1, 2016, the Plan early adopted ASU and retrospectively applied ASU for all periods presented. As a result, the Plan s investment in pooled separate accounts, which are valued using the net asset value per share as a practical expedient, were removed from the fair value hierarchy as of, and the updated presentation can be seen in Note 4. RECLASSIFICATIONS Certain reclassifications have been made to the prior period financial statements to conform to the current year presentation. There was no impact to the prior year net assets available for benefits or prior year change in net assets available for benefits. SUBSEQUENT EVENTS Management has evaluated subsequent events through July 27, 2017, the date the financial statements were available to be issued. 8

11 NOTES TO FINANCIAL STATEMENTS Note 3 INFORMATION CERTIFIED BY THE ASSET CUSTODIANS The asset custodians, MOALIC and VALIC, have certified the following information included in the accompanying financial statements and supplemental schedules as complete and accurate: 1. Investments on the statements of net assets available for benefits as of. 2. Investment activity reported on the statement of changes in net assets available for benefits for the year ended December 31, Schedule of net assets (held at year end) as of December 31, Note 4 FAIR VALUE MEASURMENTS The framework for measuring fair value provides a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (level 1) and the lowest priority to unobservable inputs (level 3). The three levels of the fair value hierarchy under FASB ASC 820 are described as follows: Level 1 - Inputs to the valuation methodology are unadjusted quoted prices for identical assets or liabilities in active markets that the Plan has the ability to access. Level 2 - Inputs to the valuation methodology include Quoted prices for similar assets or liabilities in active markets; Quoted prices for identical or similar assets or liabilities in inactive markets; Inputs other than quoted prices that are observable for the asset or liability; Inputs that are derived principally from or corroborated by observable market data by correlation or other means. If the asset or liability has a specified (contractual) term, the Level 2 input must be observable for substantially the full term of the asset or liability. Level 3 - Inputs to the valuation methodology are unobservable and significant to the fair value measurement. The asset or liability's fair value measurement level within the fair value hierarchy is based on the lowest level of any input that is significant to the fair value measurement. Valuation techniques used need to maximize the use of observable inputs and minimize the use of unobservable inputs. Following is a description of the valuation methodologies used for assets measured at fair value. There have been no changes in the methodologies used at. General accounts: Valued at amortized cost, or contract value, which is deemed to be fair value. Pooled separate accounts: Valued using net asset value per share as a practical expedient. Stated at the corresponding unit value of the pooled separate account. The estimated fair value of separate account assets are based on the fair value of the underlying assets owned by the separate account and generally based on observable valuation inputs. 9

12 NOTES TO FINANCIAL STATEMENTS The following table sets forth by level, within the fair value hierarchy, the Plan s assets at fair value as of December 31: 2016 Level 1 Level 2 Level 3 Total General accounts $ - $ - $722,428 $722,428 Investments measured at the net asset value (a) ,103,413 Investments at fair value $0 $0 $722,428 $4,825, Level 1 Level 2 Level 3 Total General accounts $ - $ - $551,202 $551,202 Investments measured at the net asset value (a) ,692,109 Investments at fair value $0 $0 $551,202 $4,243,311 (a) In accordance with Subtopic , certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy. The fair value amounts presented in this table are intended to permit reconciliation of the fair value hierarchy to the line items presented in the statement of net assets available for benefits. The following table sets forth a summary of changes in the fair value of the Plan s level 3 assets for the year ended December 31, 2016: General Accounts Beginning balance $551,202 Contributions 32,311 Distributions (84,510) Interfund transfers 209,554 Net appreciation 14,067 Fees (196) Ending balance $722,428 10

13 NOTES TO FINANCIAL STATEMENTS The following table represents the Plan s level 3 financial instruments, the valuation techniques used to measure the fair value of those financial instruments, and the significant unobservable inputs and the ranges of values for those inputs: 2016 Range of Valuation Unobservable Significant Instrument Fair Value Technique Inputs Values General accounts $722,428 Discounted cash flow Crediting rate [1] 1% - 3% (Income approach) 2015 Range of Valuation Unobservable Significant Instrument Fair Value Technique Inputs Values General accounts $551,202 Discounted cash flow Crediting rate [1] 1% - 3% (Income approach) [1] The crediting rate represents average renewal market rates applied to new funds deposited as well as expected rollover rate and an average withdrawal factor. The following table summarize investments measured at fair value based on net asset value as a practical expedient per share as of December 31: 2016 Fair Unfunded Redemption Redemption Value Commitment Frequency Notice Period Pooled separate accounts $4,103,413 n/a Daily None* 2015 Fair Unfunded Redemption Redemption Value Commitment Frequency Notice Period Pooled separate accounts $3,692,109 n/a Daily None* * There may be redemption restrictions if the Plan is in discontinuance or if a Plan participant has been placed on restrictions due to market timing 11

14 NOTES TO FINANCIAL STATEMENTS Note 5 GROUP ANNUITY CONTRACTS WITH INSURANCE COMPANIES The General Accounts of MOALIC and VALIC are credited with earnings on the underlying investments and charged for participant withdrawals and administrative expenses as allowed by the Plan. The asset custodians have determined that contract value approximates fair value. Contract value as determined by the asset custodians represents contributions made under the agreement, plus earnings, less participant withdrawals and administrative expenses. Participants may ordinarily direct the withdrawal or transfer of all or a portion of their investment at contract value. There are no reserves against contract value for credit risk of the contract issuer or otherwise. The minimum guaranteed interest rate varies by participant and depends on the date the participant established their account. For the years ended, the minimum rate ranged from 1.00 percent to 3.00 percent. Note 6 PARTY-IN-INTEREST TRANSACTIONS Certain Plan investments are managed by MOALIC and VALIC, the asset custodians of the Plan. Therefore, these transactions qualify as party-in-interest transactions. Fees incurred by the Plan for the investment management services are included in net appreciation in fair value of the investment, as they are paid through revenue sharing, rather than direct payment. As described in Note 2, the Plan made a direct payment of $1,178 to the third party administrator, which was not covered by revenue sharing. The Employer pays directly any other fees related to the Plan s operations. Note 7 PLAN TERMINATION Although it has not expressed any intent to do so, the Employer has the right under the Plan to discontinue its contributions at any time and to terminate the Plan subject to the provisions of ERISA. Note 8 TAX STATUS The Plan is intended to comply with the applicable requirements of Section 403(b) of the IRC. A tax determination letter program is not yet available for IRS Section 403(b) plans through the Internal Revenue Service. The Plan administrator believes that the Plan is currently designed and being operated in compliance with applicable requirements of the IRC and as such is exempt from Federal income taxes. Accounting principles generally accepted in the United States of America require plan management to evaluate tax positions taken by the plan and recognize a tax liability if the plan has taken an uncertain position that more likely than not would not be sustained upon examination by the IRS. The Plan is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. During the course of the 2016 audit, it was discovered that certain wages (overtime, paid time off, and on-call time) were inadvertently excluded from participants eligible Plan compensation. During 2017, the Employer is taking the necessary corrective actions through the IRS Voluntary Correction Program (VCP) and does not expect the Plan s tax status to be affected. The other employer contributions receivable on the statements of net assets available for benefits is the estimated correction of $55,414 and will be contributed as a qualified non-elective contribution. 12

15 NOTES TO FINANCIAL STATEMENTS Note 9 RISK AND UNCERTAINTIES The Plan invests in various investment securities. Investment securities are exposed to various risks, such as interest rate, market, and credit risks. Due to the level of risk associated with certain investment securities, it is at least reasonably possible that changes in the values of investment securities will occur in the near term and that such changes could materially affect the participants account balances and the amounts reported in the statement of net assets available for benefits. Note 10 DELINQUENT PARTICIPANT CONTRIBUTIONS During 2016, there were instances when participant contributions totaling $31,471 were not remitted to the Plan in a timely manner. The Employer identified the delinquent participant contributions and has subsequently fully corrected them. The Plan administrator has put controls in place to ensure that participant contributions are remitted to the Plan in a timely manner going forward. Note 11 RECONCILIATION OF FINANCIAL STATEMENTS TO FORM 5500 The following is a reconciliation of net assets available for benefits per the financial statements to the Form 5500 as of December 31: Net assets available for benefits per the financial statements $4,897,494 $4,256,673 Employer contributions receivable (4,331) (4,291) Employee contributions receivable (11,908) (11,612) Other employer contributions receivable (55,414) - Excess contributions payable - 2,541 Net assets available for benefits per Form 5500 $4,825,841 $4,243,311 Changes in net assets available for benefits per the financial statements $640,821 Current year employer contributions receivable (4,331) Current year employee contributions receivable (11,908) Current year other employer contributions receivable (55,414) Prior year employer contributions receivable 4,291 Prior year employee contributions receivable 11,612 Prior year excess contributions payable (2,541) Changes in net assets available for benefits per Form 5500 $582,530 13

16 EIN Schedule 1 PLAN NUMBER 001 (1 of 2) SCHEDULE H, LINE 4i - SCHEDULE OF ASSETS (HELD AT END OF YEAR) For The Year Ended December 31, 2016 (a) (b) (c) (e) Identity of Issuer, Borrower etc. Description Current Value * MOA Interest Accumulation Fund General Account $234,460 * VALIC Fixed Account Plus General Account 160,630 * VALIC Short-term Fixed Account General Account 249,757 * VALIC Loan Collateral and Escrow Fund General Account 77,581 * MOA Aggressive Allocation Fund Pooled Separate Accounts 76,541 * MOA Conservative Allocation Fund Pooled Separate Accounts 17,813 * MOA Moderate Allocation Fund Pooled Separate Accounts 51,372 * MOA Bond Fund Pooled Separate Accounts 124,402 * MOA T Rowe Price Blue Chip Growth Fund Pooled Separate Accounts 174,454 * MOA Composite Fund Pooled Separate Accounts 58,267 * MOA Calvert VP SRI Balanced Fund Pooled Separate Accounts 26,029 * MOA Equity Index Fund Pooled Separate Accounts 344,471 * MOA Fidelity VIP Mid Cap Fund Pooled Separate Accounts 30,449 * MOA Fidelity VIP Contrafund Pooled Separate Accounts 113,287 * MOA American Funds IS New World Fund Pooled Separate Accounts 68,838 * MOA Money Market Fund Pooled Separate Accounts 52,082 * MOA Mid-Term Bond Fund Pooled Separate Accounts 68,434 * MOA Mid-Cap Equity Index Fund Pooled Separate Accounts 144,343 * MOA Mid Cap Value Fund Pooled Separate Accounts 183 * MOA International Fund Pooled Separate Accounts 97 * MOA Oppenheimer Main Street Fund /VA Pooled Separate Accounts 202 * MOA Vanguard VIF REIT Index Fund Pooled Separate Accounts 27,703 * MOA PIMCO Fund Pooled Separate Accounts 165,934 * MOA 2020 Retirement Fund Pooled Separate Accounts 236,019 * MOA 2025 Retirement Fund Pooled Separate Accounts 250,852 * MOA 2030 Retirement Fund Pooled Separate Accounts 275,100 * MOA 2035 Retirement Fund Pooled Separate Accounts 546,571 * MOA 2040 Retirement Fund Pooled Separate Accounts 55,871 * MOA 2045 Retirement Fund Pooled Separate Accounts 225,895 * MOA 2050 Retirement Fund Pooled Separate Accounts 168,407 * MOA 2055 Retirement Fund Pooled Separate Accounts 934 * MOA All America Fund Pooled Separate Accounts 944 * MOA Deutsche VSI Capital Growth VIP Pooled Separate Accounts 17,679 * MOA Small Cap Growth Fund Pooled Separate Accounts 97,702 * MOA Small Cap Value Fund Pooled Separate Accounts 54,480 * MOA American Century VP Cap Appr Fund Pooled Separate Accounts 92,935 * MOA Vanguard VIF Diversified Value Fund Pooled Separate Accounts 12,668 * MOA Vanguard VIF International Fund Pooled Separate Accounts 63,011 * VALIC Aggressive Growth Lifestyle Pooled Separate Accounts 15,786 * VALIC Asset Allocation Fund Pooled Separate Accounts 12,624 * VALIC Blue Chip Growth Fund Pooled Separate Accounts 605 * VALIC Core Bond Fund Pooled Separate Accounts 136 * VALIC Core Equity Fund Pooled Separate Accounts 123 * VALIC Dividend Value Fund Pooled Separate Accounts 976 * VALIC Emerging Economies Pooled Separate Accounts 2,556 * VALIC Foreign Value Pooled Separate Accounts 2,687 14

17 EIN Schedule 1 PLAN NUMBER 001 (2 of 2) SCHEDULE H, LINE 4i - SCHEDULE OF ASSETS (HELD AT END OF YEAR) For The Year Ended December 31, 2016 (a) (b) (c) (e) Identity of Issuer, Borrower etc. Description Current Value * VALIC Global Real Estate Fund Pooled Separate Accounts 525 * VALIC Global Social Awareness Fund Pooled Separate Accounts 443 * VALIC Growth Fund Pooled Separate Accounts 48,066 * VALIC Health Sciences Fund Pooled Separate Accounts 340 * VALIC High Yield Bond Fund Pooled Separate Accounts 144 * VALIC Inflation Protected Fund Pooled Separate Accounts 68 * VALIC International Equities Fund Pooled Separate Accounts 3,075 * VALIC International Growth Fund Pooled Separate Accounts 432 * VALIC International Opportunities Pooled Separate Accounts 2,088 * VALIC Large Cap Core Pooled Separate Accounts 8,459 * VALIC Large Capital Growth Pooled Separate Accounts 37,705 * VALIC Mid Cap Growth Fund Pooled Separate Accounts 429 * VALIC Mid Cap Index Fund Pooled Separate Accounts 14,642 * VALIC Mid Cap Strategic Growth Pooled Separate Accounts 6,639 * VALIC Mid Cap Value Fund Pooled Separate Accounts 2,992 * VALIC Moderate Growth Lifestyle Pooled Separate Accounts 13,249 * VALIC Money Market Fund Pooled Separate Accounts 10,722 * VALIC NASDAQ 100 Index fund Pooled Separate Accounts 310 * VALIC Science and Technology Fund Pooled Separate Accounts 51,273 * VALIC Small Cap Index Fund Pooled Separate Accounts 5,599 * VALIC Small Cap Special Value Fund Pooled Separate Accounts 207 * VALIC Small Cap Value Fund Pooled Separate Accounts 3,549 * VALIC Socially Responsible Fund Pooled Separate Accounts 1,636 * VALIC Stock Index Fund Pooled Separate Accounts 51,502 * VALIC Strategic Bond Fund Pooled Separate Accounts 8,436 * VALIC Value Fund Pooled Separate Accounts 13 * VALIC Vanguard Lifestrategy Growth Pooled Separate Accounts 24,335 * VALIC Vanguard Lifestrategy Moderate Pooled Separate Accounts 9,262 * VALIC Vanguard Long Term Treasury Pooled Separate Accounts 13,941 * VALIC Vanguard Long Term Inv Grade Fund Pooled Separate Accounts 432 * VALIC Vanguard Wellington Fund Pooled Separate Accounts 88,050 * VALIC Vanguard Windsor II Pooled Separate Accounts 15,388 *Indicates parties-in-interest $4,825,841 15

18 EIN Schedule 2 PLAN NUMBER 001 SCHEDULE H, LINE 4a - SCHEDULE OF DELINQUENT PARTICIPANT CONTRIBUTIONS For The Year Ended December 31, 2016 Participant Contributions Transferred Late to Plan Check here if Late Participant Loan Repayments are included: Contributions Not Corrected Total that Constitutes Nonexempt Prohibited Transactions Contributions Corrected Outside VFCP Contributions Pending Correction in VFCP Total Fully Corrected Under VFCP and PTE $31,471 $1,773 $29,698 $ - $ - 16