Solicitation Disclosure Provided by VALIC Financial Advisors, Inc.

VALIC Financial Advisors, Inc. (“VFA” or “Solicitor”) has assumed the role of a Solicitor on behalf of ProNvest, Inc., the investment adviser, and is required to make certain disclosures to you.

Solicitor is an independent marketing agent of ProNvest. Pursuant to a written solicitor agreement, Solicitor has agreed to refer prospective clients (“Clients”) to ProNvest for managed account services (“Services”). Solicitor is not authorized to act on behalf of ProNvest with any person or organization.

Solicitor will receive from ProNvest a referral fee. The fee will be paid quarterly based on the value of the assets in Your account at calendar quarter end. The annual rate at which the referral fee is payable to the Solicitor is as follows:

• 0.35% of the first $100,000 of assets in Your account;
• 0.25% of the next $150,000 of assets in Your account; and
• 0.20% of assets in excess of $250,000 in Your account.

By signing the advisory agreement with ProNvest, you acknowledge that

1. Solicitor is not acting in a fiduciary capacity in connection with this referral to ProNvest;
2. You are retaining the services of ProNvest;
3. ProNvest is providing investment advisory or management services to You;
4. You acknowledge that Solicitor is not providing investment advice; and
5. there could be similar advisory services available to you outside of your plan for lower costs.

The information below relates to two orders issued by the SEC on July 28, 2020. VFA consented to the entry of both orders without admitting or denying the findings therein.

In the first Order, the SEC found that VFA violated certain provisions of the Investment Advisers Act of 1940 (“Advisers Act”) by failing to disclose to certain Florida teachers who were potential and actual clients that VFA’s parent company made payments and provided other financial benefits to a company owned by Florida K-12 teachers’ unions, for client referrals. The SEC found that, as a result of that conduct and VFA’s failure to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder, VFA violated Sections 206(2) and 206(4) of the Advisers Act and Rules 206(4)-3 and 206(4)-7. As part of the settlement, VFA agreed to pay a $20 million penalty and to comply with certain under takings.

In the second Order, the SEC found that VFA violated certain provisions of the Advisers Act in connection with certain mutual fund and mutual fund share class selection practices. These practices included conflicts of interest associated with VFA’s receipt of 12b-1 fees, receipt of revenue sharing, and avoidance of transaction fees, without appropriate disclosure. The SEC found that, as a result of that conduct and VFA’s failure to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices, VFA violated Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. As part of the settlement, VFA agreed to pay disgorgement of $13.2 million, prejudgment interest of $2.2 million, and a civil monetary penalty of $4.5 million, as well as to comply with certain undertakings.