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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
Defined Benefit and Defined Contribution
Recordkeeping Operations System
Controls Specified by
MassMutual Business Testing Performed by KPMG LLP and Results of Tests
5.12 Accounting operations 10/1/2019-12/31/2019
associates review supporting Inquired of management and was informed that the control was
documentation for individual
payments over $500,000 to not operating effectively from 10/1/2019-12/31/2019.
determine that disbursements Exception Noted.
were processed completely and
accurately. The review is 1/1/2020-9/30/2020
evidenced by an approval email Inspected the “GA & MR Cashbook Reconciliation &
and sign-off on the “GA & MR Disbursements Checklists” and Daily Financial Control &
Cashbook Reconciliation & Specialty Team sign-offs for a selection of dates and payments
Disbursements Checklists.” An over $500,000 and determined that an accounting operations
independent MassMutual team associate reviewed supporting documentation for individual
member performs a quality payments over $500,000 as evidenced by sign-off on the “GA &
review evidenced in an oversight MR Cashbook Reconciliation & Disbursements Checklists.”
section of the same checklists to
ensure the reconciliation was Additionally, for each selection inspected the oversight section
complete and accurate. (DC) of the “GA & MR Cashbook Reconciliation Checklists” and
source documentation and determined that a quality review of
the reconciliation was performed completely and accurately by
an independent team member.
Management Response:
As part of an internal control review, it was identified that
reconciliations were performed but not independently reviewed
for a selection of days during the period of 10/1/2019-
12/31/2019. This exception was due to the manual nature of the
control as the reconciliations were not automatically sent to the
independent reviewers which resulted in gaps where the
independent review of reconciliations were not reviewed on a
daily basis. As of 12/31/2019, the policy has been reinforced
with the associates that perform the independent review.
Management performed a lookback assessment during the gap
period (10/1/2019-12/31/2019) by examining all the daily
checklists and determined that there was a total of 59
reconciliations that were not independently reviewed. For the 59
reconciliations identified, management performed a retroactive
independent review and determined that the reconciliation was
performed completely and accurately. In addition, management
determined that no adjustments were necessary as a result of
the lookback assessment.
MassMutual Defined Benefit and Defined Control Objectives, Related Controls and Tests of
Contribution Recordkeeping Operations System Operating Effectiveness
54

