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CORRESP
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CORRESP

 SunAmerica Asset

Management, LLC

 Harborside 5

 185 Hudson Street

Suite 3300

 Jersey City, NJ 07311

www.aig.com

 Christopher J. Tafone

 Vice President

 SunAmerica Asset

Management, LLC

 Associate General Counsel

AIG Life & Retirement

T +1 201 324 6390

 F +1 201 324 6364

christopher.tafone@aig.com

 January 28, 2020

 VIA
EDGAR

 Securities and Exchange Commission

 Division
of Investment Management

 100 F Street, N.E.

 Washington, DC
20549

 Attention: Jennifer Hardy

Re:

 VALIC Company I (the “Registrant”)

Securities Act File No. 002-83631

Investment Company Act File
No. 811-03738

 Dear Ms. Hardy:

This letter responds to supplemental comments provided by the staff of the Division of Investment Management (the “Staff”) of the
Securities and Exchange Commission (the “SEC”) on January 24, 2020, and January 27, 2020, in connection with a letter filed by the Registrant on January 23, 2020, with respect to Staff comments (the “Response
Letter”) received on Post-Effective Amendment No. 86 to the Registrant’s Registration Statement on Form N-1A under the Securities Act of 1933, as amended, and Amendment No. 85 to the Registrant’s Registration Statement under
the Investment Company Act of 1940, as amended (the “Amendment”). The Amendment contains the prospectus and statement of additional information (“SAI”) for the Global Strategy Fund (the “Fund”).

For your convenience, the substance of the Staff’s comments has been restated below to the best of the Registrant’s understanding in
italicized text. The Registrant’s responses to each comment are set out immediately under the restated comment. A Post-Effective Amendment to the Registration Statement, which reflects changes made in response to the Staff’s comments,
along with changes made to update certain other information in the Registration Statement will be filed

separately. Defined terms, unless otherwise defined herein, have the meanings given them in the Amendment or the Response Letter.

I.         General

 Comment 1:

 Please file your responses to the Staff’s comments as correspondence with the SEC via EDGAR.

 Response 1:

 The Registrant will respond as requested.

 Comment 2:

 Please note that the Staff cannot assess whether the Registrant’s changes are responsive to its comments without
seeing revised disclosure. The Staff may have additional comments following its review. Please provide the proposed revised disclosure in response to the comments received on January 9, 2020.

 Response 2:

 The Registrant acknowledges the comment. The Registrant has provided below the proposed revised disclosure to the
applicable comments received on January 9, 2020. In addition, attached hereto as Exhibit A and Exhibit B are revised investment strategies of the Fund with respect to Item 4 and Item 9, respectively.

 Comment 5:     In the second sentence of the subsection entitled “Fund Summary:
Global Strategy Fund – Principal Investment Strategies of the Fund,” please specifically spell out the name of the MSCI ACWI Index.

 Response 5:     Please see paragraph 2 of Exhibit A.

 Comment 6:     In the subsection entitled “Fund Summary: Global Strategy Fund –
Principal Investment Strategies of the Fund,” in regard to debt obligations, please disclose any requirement as to duration and if there are requirements as to duration, please provide a definition and an example of duration. For example,
duration measures sensitivity to interest rates and not time and provide an example of duration (i.e., if the portfolio has a duration of 3 years and interest rates increase by 1% than the portfolio would decline in value by approximately 3%.) The
example should be in response to Item 9 disclosure. Please also explain in the risk disclosure that a longer duration tends to mean a greater sensitivity to changes in interest rates which typically correspond to higher volatility and higher
risk.

 Response 6:    The Registrant submits that the Fund may invest in debt obligations of any
duration and has revised the disclosure in the above-referenced subsection accordingly. Please see paragraph 7 of Exhibit A.

 In addition, the Registrant has revised “Interest Rate Risk” to read as follows:

 Interest Rate Fluctuations Risk. Fixed income securities may be subject to volatility due to changes in interest
rates. Duration is a measure of interest rate risk that indicates how price-sensitive a bond is to changes in interest rates. Longer-term and lower coupon bonds tend to be more sensitive to changes in interest rates. Interest rates have been
historically low, so the Fund faces a heightened risk that interest rates may rise. For example, a bond with a duration of

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 three years will decrease in value by approximately 3% if interest rates increase by 1%. Recent and
potential future changes in monetary policy made by central banks and/or their governments are likely to affect the level of interest rates.

 Comment 7:    In the subsection entitled “Fund Summary: Global Strategy
Fund – Principal Investment Strategies of the Fund,” please provide examples of when the “mix of investments will be adjusted.”

 Response 7:    Please see paragraph 7 of Exhibit A.

 Comment 8:    In the subsection entitled “Fund Summary: Global Strategy
Fund – Principal Investment Strategies of the Fund,” please provide more details about how the debt and money market investments will be chosen for purchase and how the adviser determines when to sell an investment. Please briefly disclose
these details in this subsection and in more detail in Item 9. Please also disclose how the adviser determines when the equity investments will be sold briefly in this subsection and in more detail in Item 9. Please describe the four investment
style factors – quality, value, momentum and low volatility – in more detail in the Item 9 disclosure and discuss how these factors are weighted.

 Response 8:    Please see paragraphs 6 and 7 of Exhibit A. Please also see
paragraphs 2 through 8 of Exhibit B.

 Comment 9:    In the subsection entitled “Fund Summary: Global Strategy
Fund – Principal Investment Strategies of the Fund,” please move the statement, “[i]f the value of the assets of the Fund goes down, you could lose money” to the subsection entitled “Fund Summary: Global Strategy Fund –
Principal Risks of Investing in the Fund,” pursuant to Item 4(b)(1)(i) of Form N-1A.

 Response 9:    The Fund has revised the subsection entitled “Fund Summary:
Global Strategy Fund – Principal Risks of Investing in the Fund” to read in relevant part (additions bolded and underlined):

 Principal Risks of Investing in the Fund

 As with any mutual fund, there can be no assurance that the Fund’s investment objective will be met
or that the net return on an investment in the Fund will exceed what could have been obtained through other investment or savings vehicles. Shares of the Fund are not bank deposits and are not guaranteed or insured by any bank, government entity or
the Federal Deposit Insurance Corporation. If the value of the assets of the Fund goes down, you could lose money.

 The following is a summary of the principal risks of investing in the Fund.

 Comment 12:    In the subsection entitled “Fund Summary: Global Strategy
Fund – Principal Risks of Investing in the Fund – Derivatives Risk,” please discuss the risks from currency index futures contracts and financial futures contracts.

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 Response 12:    The Registrant has added “Futures Risk” to the subsections entitled
“Fund Summary: Global Strategy Fund – Principal Risks of Investing in the Fund” and “Investment Glossary — Investment Risks” as follows:

 Futures Risk. A futures contract is considered a derivative because it derives its value from the price of
the underlying currency, security or financial index. The prices of futures contracts can be volatile and futures contracts may lack liquidity. In addition, there may be imperfect or even negative correlation between the price of a futures contract
and the price of the underlying currency, security or financial index.

 Comment 13:    In the subsection entitled “Fund Summary: Global Strategy Fund –
Performance Information,” please provide the disclosure required by Item 4(b)(2); Instruction 2(b) of Form N-1A in regard to the blended index.

 Response 13:    The Registrant has added the following disclosure with respect to the blended
index in the above-referenced subsection:

 Fund management believes the blended index provides additional comparative performance information and represents the
Fund’s overall investment strategies and portfolio composition.

 Comment 14:    In the subsection entitled “Fund Summary: Global Strategy Fund –
Purchases and Sales of Portfolio Shares,” please clarify what is meant by the statement, “[t]he prospectus (or other offering document) for your Variable Contract may contain additional information about purchase and redemptions of the
Fund’s shares.” Please state whether the prospectus contains the information.

 Response 14:    The Registrant has revised the last sentence of the above-referenced
subsection as follows (additions bolded and underlined; deletions in strikethrough text):

 The prospectus (or other offering document) for your Variable Contract may contains
additional information about purchases and redemptions of the Fund’s shares.

 Comment 17:    In the seventh paragraph of the subsection entitled “Additional
Information About the Fund’s Investment Objective, Strategies and Risks,” please provide more details regarding equity and debt investments. Please also explain

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 in general terms how the Fund’s sub-adviser decides which securities to buy and sell (e.g., for an equity fund,
discuss, if applicable, whether the fund emphasizes value or growth or blends the two approaches (see Item 9(b)(2) of Form N-1A)).

 Response 17:    Please see Exhibit B.

 Comment 23:    In the second paragraph of the subsection entitled “Management – How
VALIC is Paid for its Services,” please provide updated information in regard to the approval of the Investment Advisory Agreement, which is required to be reapproved on an annual basis.

 Response 23:    The Registrant has revised the first sentence of the second paragraph in the
above-referenced subsection to read as follows (additions bolded and underlined; deletions in strikethrough text):

 A discussion of the basis for the Board of Directors’ approval of the investment advisory agreement will
be is available in VC I’s semi-annual report for the period ended November 30, 20189.

 Comment 25:    The fee table states that only the advisory fee is being waived. Accordingly,
in the last sentence of the subsection entitled “Management – How VALIC is Paid for its Services,” please delete the reference to “or reimbursing certain expenses” or revise the fee table disclosure accordingly. Please also
describe the terms of the management fee waiver.

 Response 25:    The Registrant has revised the last paragraph of the above-referenced subsection
to read (additions bolded and underlined; deletions in strikethrough text):

 The Investment Advisory Agreement entered into with the Fund does not limit how much the Fund pays in monthly expenses each
year. However, VALIC has contractually agreed to cap certain Fund expenses by waiving a portion of its advisory fee or reimbursing certain expenses, as shown in the Annual Fund Operating Expenses table in the Fund’s Summary.
The Fund’s Advisory Fee Waiver Agreement may be modified or discontinued prior to September 30, 2021, only with the approval of the Board of Directors of VC I, including a majority of the directors who are not “interested
persons” of VC I as defined in the 1940 Act.

 Comment 28:    In the section entitled “Investment Restrictions,” please clarify
what the phrase “and/or the prospectus of the issuing company” is referring to in the fourth paragraph.

 Response 28:    The Registrant has revised the first sentence of the fourth paragraph in the
above-referenced section to read as follows (additions bolded and underlined):

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 In applying the limitations on investments in any one industry (concentration), the Fund may use industry classifications
based, where applicable, on industry classification guides such as Baseline, Bridge Information Systems, Reuters, or S&P Stock Guide, Global Industry Classification Standard information obtained from Bloomberg L.P. and Moody’s
International, or Barra, and/or the industry classifications set forth in the prospectus of the issuing company of the investment.

 Comment 29:    In the subsection entitled “Investment Restrictions – Fundamental
Investment Restrictions – Borrowing,” it states that “[t]he Fund may borrow money in amounts up to 331⁄3% of the value of its total assets for
temporary or emergency purposes.” This language is not an accurate restatement of Section 18 limitations. Please add an explanatory note clarifying what is permitted by applicable law, including for temporary or emergency purposes, which is
limited to 5%.

 Response 29:    The Registrant submits that the above-referenced language accurately reflects
the Fund’s fundamental investment restriction regarding borrowing and may only be changed with shareholder approval. The Registrant has, however, added the following explanatory note:

 Notes: The 1940 Act permits the Fund to borrow money in amounts of up to one-third of the Fund’s total
assets from banks for any purpose, and to borrow up to an additional 5% of the Fund’s total assets from banks or other lenders for temporary purposes. (The Fund’s total assets include the amounts being borrowed.) To limit the risks
attendant to borrowing, the 1940 Act requires the Fund to maintain an “asset coverage” of at least 300% of the amount of its borrowings (other than the 5% temporary borrowings); provided that in the event that the Fund’s asset
coverage falls below 300%, the Fund is required to reduce the amount of its borrowings so that it meets the 300% asset coverage threshold within three days (not including Sundays and holidays). Asset coverage means the ratio that the value of the
Fund’s total assets (including amounts borrowed), minus liabilities other than borrowings, bears to the aggregate amount of all borrowings. Certain trading practices and investments may be considered borrowings and therefore subject to the 1940
Act restrictions. The investment restriction will be interpreted to permit the Fund to engage in trading practices and investments that may be considered borrowings to the extent consistent with the 1940 Act. Short-term credits necessary for the
settlement of securities transactions and arrangements with respect to securities lending are not considered to be borrowings under the restriction. Practices and investments that may involve leverage but are not considered to be borrowings are not
subject to the restriction.

 Comment 30:    In the subsection entitled “Investment Restrictions – Fundamental
Investment Restrictions – Concentration,” it states that the Fund “may not concentrate its investments.” Please add an explanatory note as to what concentration means (i.e., 25% or more in an industry).

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 Response 30: The Registrant has added the following explanatory note:

 Notes: The 1940 Act does not define what constitutes “concentration” in an industry. The SEC
staff has taken the position that investment of 25% or more of a fund’s total assets in one or more issuers conducting its principal activities in the same industry or group of industries constitutes concentration. It is possible that
interpretations of concentration could change in the future. A fund that invests a significant percentage of its total assets in a single industry may be particularly susceptible to adverse events affecting that industry and may be riskier than a
fund that does not concentrate in an industry. The fundamental investment restriction w