The Variable Annuity Life Insurance Company

• A percentage of assets under your management

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

$32,943,851,020 as of October 2026, filing dated July 9, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for investment companies (and business development companies)
• Selection of other advisers (including private fund managers)

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

1971 (54 years)

Employees

Total: 1,700. Performing investment advisory functions: 5.

Wrap fee program participation

No.

States registered or notice-filed

Not reported.

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

14 Reports 14 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Criminal matters Items 11.A and 11.B

• 11.A(2) In the past ten years, has the firm or an advisory affiliate been charged with a felony?

Regulatory matters Items 11.C to 11.G

• 11.C(1) Has the SEC or the CFTC ever found that the firm or an advisory affiliate made a false statement or omission?
• 11.C(2) Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
• 11.C(3) Has the SEC or the CFTC ever found that the firm or an advisory affiliate was a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• 11.C(4) Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.C(5) Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?
• 11.D(1) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.D(5) Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's activity?
• 11.E(1) Has a self-regulatory organization (such as FINRA) or a commodities exchange ever found that the firm or an advisory affiliate made a false statement or omission?
• 11.E(2) Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?
• 11.E(3) Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• 11.G Is the firm or an advisory affiliate now the subject of a regulatory proceeding that could result in a yes answer to any part of 11.C, 11.D, or 11.E?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $35,307,382,680 in the October 2021 data and $32,943,851,020 in the October 2026 data, down 7%.

Total employees: 2,200 in October 2021 and 1,700 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. May 2026
   • Item 11 disclosure answers changed: 14 yes answers, previously 15 (now no: 11.A(1)).
2. April 2026
   • Employees performing advisory functions went from 6 to 5.
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.