SecProbe.io

CORRESP
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CORRESP

 787 Seventh Avenue

 New York, NY 10019-6099

 Tel: 212 728 8000

Fax: 212 728 8111

 April 22, 2024

VIA EDGAR

 Ms. Soo Im-Tang, Esq.

 Division of Investment Management

Securities and Exchange Commission

 100 F Street, NE

Washington, D.C. 20549

Re:
 Core Bond Fund, Emerging Economies Fund and International Value Fund, each a series of VALIC Company I

 Securities Act File No. 002-83631

Investment Company Act File No. 811-03738

Dear Ms. Im-Tang:

On behalf of Core Bond Fund, Emerging Economies Fund and International Value Fund (the “Funds” and each, a
“Fund”), each a series of VALIC Company I (the “Registrant”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) on April 5, 2024 regarding Post-Effective Amendment No. 116 to the Registrant’s Registration Statement on Form N-1A (the “Registration Statement”) under the
Securities Act of 1933, as amended, and Amendment No. 115 under the Investment Company Act of 1940, as amended, which was filed with the Commission on February 22, 2024.

The Staff’s comments, which are set forth below in italicized text, have been summarized to the best of our
understanding. We have discussed the Staff’s comments with representatives of the Registrant. The Registrant’s responses to the Staff’s comments are set out immediately under the restated comment. Please note that we have not
independently verified information provided by the Registrant. A Post-Effective Amendment to the Registration Statement (the “Amendment”), 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 at a later date. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement.

BRUSSELS CHICAGO FRANKFURT HOUSTON LONDON LOS
 ANGELES MILAN

 MUNICH NEW
YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON

 April 22, 2024

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 Comment No. 1:

 Please file your responses to the Staff’s comments as a correspondence filing via EDGAR five business days prior to
the effective date of the Amendment.

 Response No. 1:

 The Registrant confirms that it will file its responses in a correspondence filing within five business days from the
effective date of the Amendment.

 Core Bond Fund

 Comment No. 2:

 The third paragraph of the subsection of the Prospectus entitled “Fund Summary: Core Bond Fund –
Principal Investment Strategies of the Fund,” states that the Fund may invest up to 40% of its total assets in U.S. dollar-denominated fixed-income securities issued by foreign issuers, including fixed-income securities issued by issuers
in emerging markets. Please define emerging markets.

 Response No. 2:

 The disclosure will be updated in the Amendment as follows:

 Up to 40% of the Fund’s total assets may be invested in U.S.
dollar-denominated fixed-income securities issued by foreign issuers, including fixed-income securities issued by issuers in emerging markets. Emerging market countries are countries that major international financial institutions and
financial organizations, such as the World Bank and Bloomberg, generally consider to be less economically mature than developed nations, and include most countries in the world except Australia, Canada, Japan, New Zealand, the U.S., the United
Kingdom and most western European countries and Hong Kong. These fixed-income securities are rated investment grade or higher at the time of investment (or the unrated equivalent). However, the subadvisers are not required to dispose of a
security if its rating is downgraded.

 Comment No. 3:

 The fifth paragraph of the subsection of the Prospectus entitled “Fund Summary: Core Bond Fund –
Principal Investment Strategies of the Fund,” states that, although the Fund does not routinely invest in equity securities, it may invest in equity securities from time-to-time up to 20% of the Fund’s net assets. Please
consider including equity securities as a principal risk of the Fund in light of this statement.

 Response No. 3:

 Investment in equity securities will not be a principal investment strategy of the Fund and, as such, the disclosure noted
by the Staff will be deleted in the Amendment and a risk factor regarding investment in equity securities will not be added.

 Comment No. 4:

 Please provide the completed fee table with your responses to the Staff’s comments.

 Response No. 4:

 The completed fee table for each Fund is provided below:

 April 22, 2024

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 Core Bond Fund

 Fees and Expenses of the Fund

 This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund. The
table and the example below do not reflect the separate account fees charged in the variable annuity or variable life insurance policy (“Variable Contracts”) in which the Fund is offered. If separate account fees were shown, the
Fund’s annual operating expenses would be higher. Please see your Variable Contract prospectus for more details on the separate account fees.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

 Management Fees

0.41%

 Other Expenses

0.09%

 Total Annual Fund Operating Expenses

0.50%

 Fee Waivers and/or Expense
Reimbursements1

0.03%

 Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements1

0.47%

 (1)  The Fund’s investment adviser, The Variable Annuity Life
Insurance Company (“VALIC”), has contractually agreed to waive its advisory fee until September 30, 2025, so that the advisory fee payable by the Fund to VALIC equals 0.47% on the first $200 million of the Fund’s average daily net
assets, 0.42% on the next $300 million of the Fund’s average daily net assets and 0.37% on average daily net assets over $500 million. This agreement may be modified or discontinued prior to such time only with the approval of the Board of
Directors of VALIC Company I (“VC I”), including a majority of the directors who are not “interested persons” of VC I as defined in the Investment Company Act of 1940, as amended.

 Emerging Economies Fund

 Fees and Expenses of the Fund

 This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund. The
table and the example below do not reflect the separate account fees charged in the variable annuity or variable life insurance policy (“Variable Contracts”) in which the Fund is offered. If separate account fees were shown, the
Fund’s annual operating expenses would be higher. Please see your Variable Contract prospectus for more details on the separate account fees.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

 April 22, 2024

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 Management Fees

0.77%

 Other Expenses

0.19%

 Total Annual Fund Operating Expenses

0.96%

 International Value Fund

 Fees and Expenses of the Fund

 This table describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund. The
table and the example below do not reflect the separate account fees charged in the variable annuity or variable life insurance policy (“Variable Contracts”) in which the Fund is offered. If separate account fees were shown, the
Fund’s annual operating expenses would be higher. Please see your Variable Contract prospectus for more details on the separate account fees.

Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

 Management Fees

0.70%

 Other Expenses

0.15%

 Acquired Fund Fees and Expenses1

0.01%

 Total Annual Fund Operating
Expenses1

0.86%

 Fee Waivers and/or Expense
Reimbursements2

0.07%

 Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements1,2

0.79%

  

 (1)  The Total Annual Fund Operating Expenses for the Fund do not
correlate to the ratio of net expenses to average net assets provided in the Financial Highlights table of the Fund’s annual report, which reflects the net operating expenses of the Fund and does not include Acquired Fund Fees and Expenses.
“Acquired Fund Fees and Expenses” include fees and expenses incurred indirectly by the Fund as a result of investments in shares of one or more Underlying Funds.

 (2)  The Fund’s investment adviser, The Variable Annuity Life
Insurance Company (“VALIC”), has contractually agreed to waive its advisory fee until September 30, 2025, so that the advisory fee payable by the Fund to VALIC equals 0.66% on the first $250 million of the Fund’s average
daily net assets, 0.61% on the next $250 million of the Fund’s average daily net assets, 0.56% on the next $500 million of the Fund’s average daily net assets and 0.51% on average daily net assets over $1 billion. This
agreement may be modified or discontinued prior to such time only with the approval of the Board of Directors of the Fund, including

 April 22, 2024

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 a majority of the directors who are not “interested persons” of the Fund as defined in the Investment Company Act
of 1940, as amended.

 Emerging Economies Fund

 Comment No. 5:

 The Staff notes that disclosure in the Prospectus states the Fund may invest in other investment companies. Accordingly,
please confirm that no Acquired Fund Fees and Expenses (“AFFE”) are anticipated for the first year or add such AFFE in the fee table.

 Response No. 5:

 The Registrant confirms that no AFFE are anticipated for the first year.

 International Value Fund

 Comment No. 6:

 The first paragraph of the subsection of the Prospectus entitled “Fund Summary: International Value Fund
– Principal Investment Strategies of the Fund,” states that the Fund invests at least 80% of its net assets in equity securities of foreign issuers. Please define foreign issuers.

 Response No. 6:

 The Registrant notes that it defines “foreign issuer” with respect to the criteria listed in the third paragraph
of this subsection, which sets forth how the Registrant will determine whether an issuer is economically tied to a non-U.S. country. The Registrant will clarify in the Amendment that it defines foreign issuers with respect to whether such issuer is
economically tied to a non-U.S. country.

 Comment No. 7:

 Please confirm whether the Fund’s investment adviser can recoup any fees pursuant to the advisory fee waiver
arrangement described in footnote 2 to the fee table. If fees may be recouped, please disclose that the Fund may only make repayments to the investment adviser if such payment does not cause the Fund’s expense ratio to exceed both (i) the
expense cap in place at the time such amounts were waived and (ii) the Fund’s current expense cap.

 Response No. 7:

 The Registrant confirms that fees are not recoupable by the investment adviser pursuant to the advisory fee waiver
arrangement.

 Comment No. 8:

 The third paragraph of the subsection of the Prospectus entitled “Fund Summary: International Value Fund
– Principal Investment Strategies of the Fund,” states that the Fund will consider the domicile of the issuer’s senior management in determining whether an issuer is economically tied to a non-U.S. country. Please delete or
explain why domicile of issuer’s senior management is a reasonable basis for determining the locality of a company. Please provide any third party sources that support your position. The Staff may have additional comments based on our
response.

 Response No. 8:

 The Fund has described what it considers a non-U.S. security using plain English language, which is a summary of how it
applies Bloomberg’s Country of Risk definition. Country of Risk is a proprietary Bloomberg test primarily consisting of

 April 22, 2024

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 four other Bloomberg-defined factors: Country of Domicile, Country of Listing, Country of Largest Revenue, and Reporting
Currency. Country of Domicile, as defined by Bloomberg, is “The ISO (International Organization for Standardization) code of the country where the company’s senior management is located. For covered warrants the country of the issuer
is returned. For uncovered warrants, the country of the underlying security is returned.” This is the same analysis that is used for the determination of foreign securities for various Bloomberg indices, and as a result is reasonable for
the Fund to use in its determination of what is considered a foreign security. Prior to the adoption of Country of Risk, the Fund or its affiliates in the Fund Complex used Country of Domicile and/or Country of Listing as the only determination
of whether a security was considered non-U.S. Moving to Country of Risk incorporated additional economic factors into the analysis, such as revenue and reporting currency. For additional information, see Bloomberg’s Global Equity
Indices Methodology, located at: https://assets.bbhub.io/professional/sites/10/Bloomberg-Global-Equity-Indices-Methodology.pdf.

 Comment No. 9:

 The fourth paragraph of the subsection of the Prospectus entitled “Fund Summary: International Value Fund
– Principal Investment Strategies of the Fund,” states that Goldman Sachs employs a fundamental investment process that may integrate ESG factors. Please disclose (i) whether the adviser applies the ESG criteria with respect to
every investment the Fund makes or only some of its investments, and (ii) whether an investment can be made in a company that scores poorly in ESG criteria if it scores strongly in other non-ESG factors.

 Response No. 9:

 Although GSAM may choose to integrate ESG factors into its fundamental investment process, it is not a requirement.
Furthermore, the identification of risk related to an ESG factor will not necessarily exclude a particular security or sector that, in GSAM’s view, is otherwise suitable and attractively priced for investment. For clarity, the fourth paragraph
of the section of the prospectus entitled “Additional Information About the Fund’s Investment Objective, Strategies and Risks—International Value Fund” will be revised and a new fifth paragraph will be added as
follows:

 The Fund is sub-advised by both Goldman Sachs Asset Management, L.P.
(“GSAM”) and Columbia Management Investment Advisers, LLC (“Columbia”). GSAM selects investments using an investment philosophy and a valuation discipline designed to identify what GSAM believes are well-positioned,
cash-generating businesses run by shareholder-oriented management teams. GSAM employs a fundamental investment process that may integrate environmental, social and governance factors alongside traditional fundamental factors. No one
factor or consideration is determinative in the stock selection process. In the portion of the Fund subadvised by GSAM, the Fund expects to invest a majority of its assets in a diversified portfolio of equity investments
of

 April 22, 2024

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 dividend-paying non-U.S. issuers. A substantial portion of the assets in
GSAM’s sleeve are invested in the securities of issuers located in the developed countries of Western Europe and in Australia, Japan and New Zealand. The Fund’s investments in a particular developed country may exceed 25% of its investment
portfolio.

 GSAM may integrate ESG factors alongside traditional fundamental factors as
part of its fundamental research process to seek to assess overall business quality and valuation, as well as potential risks. No one factor is consideration is determinative in the stock selection process. Traditional fundamental factors that GSAM
may consider include, but are not limited to, cash flows, balance sheet leverage, return on invested capital, industry dynamics, earnings quality and profitability. ESG factors that GSAM may consider include, but are not limited to, carbon intensity
and emissions profiles, workplace health