UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM TA-1

UNIFORM FORM FOR REGISTRATION AS A TRANSFER AGENT AND FOR AMENDMENTTO REGISTRATION PURSUANT TO SECTION 17A OF THESECURITIES EXCHANGE ACT OF 1934
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GENERAL: Form TA-1 is to be used to register or amend registration as a transfer agent with the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation or the Securities and Exchange Commission pursuant to Section 17A of the Securities Exchange Act of 1934. Read all instructions before completing this form. Please print or type all responses.
Form Version:3.2.0
1(a).  Filer CIK: 0001202048
1(c). Live/Test Filing?
X Live    Test
1(e). Is this filing an amendment to a previous filing?
X Yes
1(e)(i).  File Number: 084-006057

2. Appropriate regulatory agency (check one):
X Securities and Exchange Commission
   Board of Governors of the Federal Reserve System
   Federal Deposit Insurance Corporation
   Comptroller of the Currency
   Office of Thrift Supervision

3(a).  Full Name of Registrant:
VALIC Retirement Services Company
3(a)(i).  Previous name, if being amended:

3(b).  Financial Industry Number Standard (FINS) number:502575
3(c).  Address of principal office where transfer agent activities are, or will be, performed:
3(c)(i).  Address 1
2929 Allen Parkway, L4-01
3(c)(ii).  Address 2

3(c)(iii).  City
Houston
3(c)(iv).  State or Country
TX
TEXAS
3(c)(v).  Postal Code
77019
3(d). Address of principal office where transfer agent activities are, or will be, performed:
   Yes X No
If `yes,` provide address(es):
3(e).  Telephone Number (Include Area Code)
713-831-3150

4. Does registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Question 3(c) above?
X Yes    No
If `yes,` provide address(es):
4(a)(i).  Address 1
PO Box 15648
4(a)(ii).  Address 2

4(a)(iii).  City
Amarillo
4(a)(iv).  State or Country
TX
TEXAS
4(a)(v).  Postal Code
79105

5. Does registrant act, or will it act, as a transfer agent solely for its own securities and/or securities of an affiliate(s)?
   Yes X No

6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions?
   Yes X No
If `yes,` provide the name(s) and address(es) of all service companies engaged, or that will be engaged, by the registrant to perform its transfer agent functions:

7. Has registrant been engaged, or will it be engaged, as a service company by a named transfer agent to perform transfer agent functions?
   Yes X No
If `yes,` provide the name(s) and File Number(s) of the named transfer agent(s) for which the registrant has been engaged, or will be engaged, as a service company to perform transfer agent functions:

Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select `Not Applicable.`

8. Is registrant a:
X Corporation
   Partnership
   Sole Proprietorship
   Other
   Not Applicable

Section for Initial Registration and for Amendments Reporting Additional Persons. (Corporation or Partnership)

8(a)(i).  Full Name: Kurt W. Bernlohr
8(a)(ii).  Relationship Start Date: 04/08/2009
8(a)(iii).  Title or Status: Director and Senior Vice President
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: N. Scott Gillis
8(a)(ii).  Relationship Start Date: 06/28/2002
8(a)(iii).  Title or Status: Director, Senior Vice President and Ctlr
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Sharla A. Jackson
8(a)(ii).  Relationship Start Date: 03/02/2006
8(a)(iii).  Title or Status: Director and Chief Operating Officer
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Brenda Simmons
8(a)(ii).  Relationship Start Date: 03/09/2010
8(a)(iii).  Title or Status: President
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Louis V. McNeal
8(a)(ii).  Relationship Start Date: 09/05/2008
8(a)(iii).  Title or Status: Vice President and Treasurer
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
X
8(a)(vi).  Relationship End Date:

8(a)(i).  Full Name: Katherine Stoner
8(a)(ii).  Relationship Start Date: 03/02/2006
8(a)(iii).  Title or Status: Vice President and Secretary
8(a)(iv). Ownership Code:
X NA - 0 to 5%
   A - 5% up to 10%
   B - 10% up to 25%
   C - 25% up to 50%
   D - 50% up to 75%
   E - 75% up to 100%
8(a)(v). Control Person:
  
8(a)(vi).  Relationship End Date:


9.  Does any person or entity not named in the answer to Question 8:
9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant; or . . . .
X Yes    No    NA
9(a)(i).  Exact name of each person or entity:
American General Life Insurance Company, AGC Life Insurance Company, AIG Life Holdings, Inc., American International Group, Inc., and the AIG Credit F
9(a)(ii).  Description of the Agreement or other basis:
The Variable Annuity Life Insurance Company ("VALIC") is 100 percent owned by American General Life Insurance Company, which 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 American International Group, Inc. The AIG Credit Facility Trust ("Trust") is a control person for AIG. The Trust owns all AIG Series C Convertible Preferred Stock, which represents a majority of outstanding voting power in AIG. Nothing herein shall be construed as an acknowledgement or representation that any provision of federal securities laws or rules or forms thereunder or any other statute or regulation applies to or includes the Trust, its trustees or the U.S. Treasury, or that the Trust, its trustees or the U.S. Treasury controls VALIC or VRSCO.
9(b). wholly or partially finance the business of applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others ? . . . . . . . . . . . . . . . . . . . . . . . . . .
   Yes X No
9(b)(i).  Exact name of each person or entity:

9(b)(ii).  Description of the Agreement or other basis:


10.  Applicant and Control Affiliate Disciplinary History:
The following definitions apply for purposes of answering this Question 10
Control affiliate - An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority.
Investment or investment related - Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker-dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association).
Involved - Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act.
10(a).  In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contender (`no contest`) to:
10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting or extortion?
   Yes X No
10(a)(2). any other felony?
   Yes X No
10(b).  Has any court in the past ten years:
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity?
X Yes    No
10(b)(1)(i).  The individuals named in the action or claim:
American International Group, Inc.
10(b)(1)(ii).  Title of Action 10(b)(1)(iii).  Date of Action
Injunction
 02/09/2006
10(b)(1)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission
10(b)(1)(v).  Description of the action or claim:
THE 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.
10(b)(1)(vi).  Disposition of action or claim:
Settled 2/17/06
10(b)(2). found that the applicant or a control affiliate was involved in a violation of investment-related statutes or regulations?
   Yes X No
10(c).  Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:
10(c)(1). found the applicant or a control affiliate to have made a false statement or omission?
X Yes    No
10(c)(1)(i).  The individuals named in the action or claim:
American International Group, Inc.
10(c)(1)(ii).  Title of Action 10(c)(1)(iii).  Date of Action
Injunction
 02/06/2006
10(c)(1)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission, Washington, DC
10(c)(1)(v).  Description of the action or claim:
THE 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.
10(c)(1)(vi).  Disposition of action or claim:
Settled 2/17/06
10(c)(2). found the applicant or a control affiliate to have been involved in a violation of its regulations or statutes?
X Yes    No
10(c)(2)(i).  The individuals named in the action or claim:
American International Group, Inc. ("AIG")
10(c)(2)(ii).  Title of Action 10(c)(2)(iii).  Date of Action
Docket SDNY - CASE NO. 06 CIV 1000
 02/09/2006
10(c)(2)(iv).  The Court or body taking the Action and location:
Securities and Exchange Commission & DOJ
10(c)(2)(v).  Description of the action or claim:
The 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.
10(c)(2)(vi).  Disposition of action or claim:
Settled 2/17/06.
10(c)(3). found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
   Yes X No
10(c)(4). entered an order denying, suspending or revoking the applicant`s or a control affiliate`s registration or otherwise disciplined it by restricting its activities?
   Yes X No
10(d).  Has any other Federal regulatory agency or any state regulatory agency:
10(d)(1). ever found the applicant or a control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical?
X Yes    No
10(d)(1)(i).  The individuals named in the action or claim:
American International Group, Inc. ("AIG")
10(d)(1)(ii).  Title of Action 10(d)(1)(iii).  Date of Action
CIV-042070
 11/30/2004
10(d)(1)(iv).  The Court or body taking the Action and location:
Department of Justice
10(d)(1)(v).  Description of the action or claim:
THE DEPARTMENT OF JUSTICE ("DOJ") FILED A CRIMINAL COMPLAINT AGAINST AIG-FP PAGIC EQUITY HOLDING CORP. ("AIG-FP PAGIC"), A WHOLLY-OWNED SUBSIDIARY OF AIG FINANCIAL PRODUCTS CORP. ("AIG-FP"), IN TURN A WHOLLY-OWNED SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, INC. ("AIG"). THE COMPLAINT ALLEGED THAT AIG-FP PAGIC VIOLATED FEDERAL SECURITIES LAWS BY AIDING AND ABETTING SUECURITIES LAW VIOLATIONS BY A PUBLIC COMPANY, PNC FINANCIAL SERVICES GROUP, INC. ("PNC"), INCONNECTION WITH A TRANSACTION ENTERED INTO IN 2001 WITH PNC THAT WAS INTENDED TO ENABLE PNC TO REMOVE CERTAIN ASSETS FROM ITS BALANCE SHEET. THE COMPLAINT ALLEGES THAT AIG-FP PAGIC KNEW, OR WAS DELIBERATELY IGNORANT IN NOT KNOWING, THAT THE PNC TRANSACTION DID NOT SATISFY THE REQUIREMENTS OF GAAP FOR NON-CONSOLIDATION OF SPECIAL PURPOSE ENTITIES. THE AIG-FP PAGIC TRANSACTION WAS THE LAST OF THREE SIMILAR TRANSACTIONS DEVELOPED, MARKETD AND ENTERED INTO BY AIG-FP AND ITS SUBSIDIARIES WITH PNC DURING 2001. THE DOJ HAS NOTIFIED AIG-FP THAT, IN ITS VIEW, AIG-FP ACTING THROUGH CERTAIN OF ITS EMPLOYEES MAY HAVE VIOLATED FEDERAL CRIMINAL LAW IN CONNECTION WITH THE PNC TRANSACTIONS AND THE MARKETING OF SIMILAR TRANSACTION STRUCTURES TO OTHER POTENTIAL COUNTERPARTIES. AIG-FP PAGIC WAS DISSOLVED FEBRUARY 3, 2006.
10(d)(1)(vi).  Disposition of action or claim:
Settled 11/30/04
10(d)(2). ever found the applicant or a control affiliate to have been involved in a violation of investment-related regulations or statutes?
X Yes    No
10(d)(2)(i).  The individuals named in the action or claim:
American International Group, Inc. ("AIG")
10(d)(2)(ii).  Title of Action 10(d)(2)(iii).  Date of Action
CIV-042070
 11/30/2004
10(d)(2)(iv).  The Court or body taking the Action and location:
Department of Justice
10(d)(2)(v).  Description of the action or claim:
THE DEPARTMENT OF JUSTICE ("DOJ") FILED A CRIMINAL COMPLAINT AGAINST AIG-FP PAGIC EQUITY HOLDING CORP. ("AIG-FP PAGIC"), A WHOLLY-OWNED SUBSIDIARY OF AIG FINANCIAL PRODUCTS CORP. ("AIG-FP"), IN TURN A WHOLLY-OWNED SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, INC. ("AIG"). THE COMPLAINT ALLEGED THAT AIG-FP PAGIC VIOLATED FEDERAL SECURITIES LAWS BY AIDING AND ABETTING SUECURITIES LAW VIOLATIONS BY A PUBLIC COMPANY, PNC FINANCIAL SERVICES GROUP, INC. ("PNC"), INCONNECTION WITH A TRANSACTION ENTERED INTO IN 2001 WITH PNC THAT WAS INTENDED TO ENABLE PNC TO REMOVE CERTAIN ASSETS FROM ITS BALANCE SHEET. THE COMPLAINT ALLEGES THAT AIG-FP PAGIC KNEW, OR WAS DELIBERATELY IGNORANT IN NOT KNOWING, THAT THE PNC TRANSACTION DID NOT SATISFY THE REQUIREMENTS OF GAAP FOR NON-CONSOLIDATION OF SPECIAL PURPOSE ENTITIES. THE AIG-FP PAGIC TRANSACTION WAS THE LAST OF THREE SIMILAR TRANSACTIONS DEVELOPED, MARKETD AND ENTERED INTO BY AIG-FP AND ITS SUBSIDIARIES WITH PNC DURING 2001. THE DOJ HAS NOTIFIED AIG-FP THAT, IN ITS VIEW, AIG-FP ACTING THROUGH CERTAIN OF ITS EMPLOYEES MAY HAVE VIOLATED FEDERAL CRIMINAL LAW IN CONNECTION WITH THE PNC TRANSACTIONS AND THE MARKETING OF SIMILAR TRANSACTION STRUCTURES TO OTHER POTENTIAL COUNTERPARTIES. AIG-FP PAGIC WAS DISSOLVED FEBRUARY 3, 2006.
10(d)(2)(vi).  Disposition of action or claim:
Settled 11/30/04
10(d)(3). ever found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
   Yes X No
10(d)(4). in the past ten years entered an order against the applicant or a control affiliate in connection with investment-related activity?
X Yes    No
10(d)(4)(i).  The individuals named in the action or claim:
American International Group, Inc. ("AIG")
10(d)(4)(ii).  Title of Action 10(d)(4)(iii).  Date of Action
CIV-042070
 11/30/2004
10(d)(4)(iv).  The Court or body taking the Action and location:
Department of Justice
10(d)(4)(v).  Description of the action or claim:
THE DEPARTMENT OF JUSTICE ("DOJ") FILED A CRIMINAL COMPLAINT AGAINST AIG-FPPAGIC EQUITY HOLDING CORP. ("AIG-FP PAGIC"), A WHOLLY-OWNED SUBSIDIARY OF AIG FINANCIAL PRODUCTS CORP. ("AIG-FP"), IN TURN A WHOLLY-OWNED SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, INC. ("AIG"). THE COMPLAINT ALLEGED THAT AIG-FP PAGIC VIOLATED FEDERAL SECURITIES LAWS BY AIDING AND ABETTING SECURITIES LAW VIOLATIONS BY A PUBLIC COMPANY, PNC FINANCIAL SERVICES GROUP, INC. ("PNC"), IN CONNECTION WITH A TRANSACTION ENTERED INTO IN 2001WITH PNC THAT WAS INTENDED TO ENABLE PNC TO REMOVE CERTAIN ASSETS FROM ITS BALANCE SHEET. THE COMPLAINT ALLEGES THAT AIG-FP PAGIC KNEW, OR WAS DELIBERATELY IGNORANT IN NOT KNOWING, THAT THE PNC TRANSACTION DID NOT SATISFY THE REQUIREMENTS OF GAAP FOR NON-CONSOLIDATION OF SPECIAL PURPOSE ENTITIES. THE AIG-FP PAGIC TRANSACTION WAS THE LAST OF THREE SIMILAR TRANSACTIONS DEVELOPED, MARKETED AND ENTERED INTO BY AIG-FP AND ITS SUBSIDIARIES WITH PNC DURING 2001. THE DOJ HAS NOTIFIED AIG-FP THAT, IN ITS VIEW, AIG-FP ACTING THROUGH CERTAIN OF ITS EMPLOYEES MAY HAVE VIOLATED FEDERAL CRIMINAL LAW IN CONNECTION WITH THE PNC TRANSACTIONS AND THE MARKETING OF SIMILAR TRANSACTION STRUCTURES TO OTHER POTENTIAL COUNTERPARTIES. AIG-FP PAGIC WAS DISSOLVED FEBRUARY 3, 2006
10(d)(4)(vi).  Disposition of action or claim:
THE SETTLEMENT WITH THE DOJ COMPRISED SEPARATE AGREEMENTS WITH AIG ANDAIG-FP AND A COMPLAINT FILED AGAINST, AND DEFERRED PROSECUTION AGREEMENT WITH, AIG-FP PAGIC. UNDER THE TERMS OF SETTLEMENT, AIG-FP PAID A MONETARY PENALTY OF $80,000,000, PLUS OTH TERMS
10(d)(5). ever denied, suspended, or revoked the applicant`s or a control affiliate`s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities?
   Yes X No
10(d)(6). ever revoked or suspended the applicant`s or a control affiliate`s license as an attorney or accountant?
   Yes X No
10(e).  Has any self-regulatory organization or commodities exchange ever:
10(e)(1). found the applicant or a control affiliate to have made a false statement or omission?
   Yes X No
10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules?
   Yes X No
10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business?
   Yes X No
10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities?
   Yes X No
10(f). Has any foreign government, court, regulatory agency, or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud?
   Yes X No
10(g). Is the applicant or a control affiliate now the subject of any proceeding that could result in a yes answer to questions 10(a) - 10(f)?
   Yes X No
10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate?
   Yes X No
10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it?
   Yes X No

ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a)
SIGNATURE: The Registrant submitting this Form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.
11(a).  Signature of Official responsible for Form:
Katherine Stoner
 11(b).  Telephone Number:
713-831-3164
11(c).  Title of Signing Officer:
Secretary
 11(d).  Date Signed (Month/Day/Year)
03/31/2010