Page 111 - NovDefComp
P. 111

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


                6.9 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     Exceptions Noted.
                were processed completely and
                accurately. The review is        1/1/2020-9/30/2020
                evidenced by sign-off on the “GA   Inspected the “GA Cashbook Reconciliation & Disbursements
                Cashbook Reconciliation &        Checklist “for a selection of dates and determined that an
                Disbursements Checklist.” An     accounting operations associate reviewed supporting
                independent MassMutual team      documentation for individual payments over $500,000 to source
                member performs a quality        documentation and determined that the payment was
                review evidenced in an oversight   authorized and approved by a DB Manager or their designate.
                section of the same checklists to
                ensure the reconciliation was    Additionally, inspected the oversight section of the “GA
                complete and accurate. (DB)      Cashbook Reconciliation & Disbursements Checklist” and
                                                 source documentation and determined that a quality review of
                                                 the reconciliations were 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
                                                             63
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