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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


                6.13 Accounting operations       10/1/2019-12/31/2019
                associates reconcile on a daily   Inquired of management and was informed that the control was
                basis that trade activity from
                Fundlinx equals cash activity as   not operating effectively from 10/1/2019-12/31/2019.
                fed from the administrative      Exception Noted.
                recordkeeping systems (CAS and
                PRS). The reconciliation is      1/1/2020-9/30/2020
                documented on the “GA & MR       Inspected the “GA & MR Daily Cash Suspense Report” for a
                Daily Cash Suspense Reports”     selection of dates and determined that an accounting operations
                and discrepancies are            associate verified that trade activity from Fundlinx equaled cash
                researched and resolved. The     activity as fed from the administrative recordkeeping systems
                verification is evidenced on the   (CAS and PRS). Also determined that the reconciliation was
                daily “GA & MR Cashbook          documented on the “GA & MR Daily Cash Suspense Reports”
                Reconciliation & Disbursements   and that a verification review was evidenced on the daily “GA &
                Checklists.” An independent team   MR Cashbook Reconciliation & Disbursement Checklists.”
                member performs a quality
                review evidenced in an oversight   Additionally, KPMG inspected the oversight section of the “GA &
                section of the same checklists to   MR Cashbook Reconciliation & Disbursements Checklists” and
                ensure the reconciliation was    source documentation and determined that a quality review of
                complete and accurate. (DB)      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
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