Page 102 - NovDefComp
P. 102

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
   97   98   99   100   101   102   103   104   105   106   107