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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                                   Defined Benefit and Defined Contribution

                                            Recordkeeping Operations



               Complementary Subservice Organization Controls (CSOCs)

               MassMutual’s systems and the controls over DB and DC Recordkeeping Operations system processing
               were designed with the assumption that certain control objectives can be achieved only if the CSOCs are
               implemented by the subservice organizations. The description includes only the controls and related control
               objectives  of  MassMutual and  excludes  the  control  objectives  and  related  controls  of  the  subservice
               organizations. The application of such CSOCs by subservice organizations support the achievement of
               control objectives identified in this report. The subservice organization control considerations presented
               below should not be regarded as a comprehensive list of all of the controls that should be employed by the
               subservice organizations.

                                                                                 Complementary Subservice
                  Subservice                                Related Control
                 Organization     Services Provided            Objective            Organization Controls
                                                                                          (CSOCs)
                DST            TRAC (Software-as-a-     Control Objective 1     CO 1 and CO 2-DST should
                               Service) DC                                      have controls to ensure that
                               Recordkeeping            Application Change      application/software
                                                        Management
                               system used by                                   development and application/
                               MassMutual DC            Control Objective 2     software changes made to
                               Midmarket Corporate                              existing applications are
                               clients. Software-as-a-  System Software         documented, authorized,
                                                        Change Management
                               Service is a subscription                        tested and approved for
                               based software           Control Objective 3     implementation.
                               distribution model in
                               which TRAC, a multi-     Physical Security and   CO 3-DST should have
                               tenant application, is   Environmental Controls  controls over physical
                                                                                security and environmental
                               developed, hosted and    Control Objective 4     protection of computer
                               maintained centrally by
                               DST and made             Logical Access          equipment and storage
                                                                                media.
                               available to MassMutual   Control Objective 5
                               and other clients over                           CO 4-DST should have
                               the Internet.            Job Processing          controls over provisioning,

                               Automated Work           Control Objective 6     termination, and
                                                                                recertification of TRAC and
                               Distribution (AWD)       Data Transmissions
                               system used by                                   AWD user access.
                               MassMutual automates                             CO 5-DST should have
                               the handling and                                 controls over the scheduling
                               distribution of hardcopy                         of production processing and
                               client and participant                           system backups, and the
                               documents. AWD is                                identification and resolution
                               hosted and maintained                            of deviations from the
                               centrally by DST and                             schedule.
                               made available to
                               MassMutual. DST’s                                CO 6-DST should have
                               services are limited to                          controls over the completion
                               System Software                                  and security of data
                               Change Management,                               transmissions, and
                               Physical Security and                            identification and resolution
                               Environmental Controls.                          of failures.



                MassMutual Defined Benefit and Defined                    Description of the System Provided by
                Contribution Recordkeeping Operations System                                     MassMutual
                                                             11
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