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Massachusetts Mutual Life Insurance Company
               1295 State Street
               Springfield, MA 01111

               MassMutual’s Assertion
               November 19, 2020

               We have prepared the description of Massachusetts Mutual Life Insurance Company’s (MassMutual or
               the Company) Defined Benefit and Defined Contribution Investment Service Operations System entitled,
               “Description of the Defined Benefit and Defined Contribution Investment Service Operations System”, for
               processing user entities’ transactions throughout the period October 1, 2019 to September 30, 2020
               (description) for user entities of the system during some or all of the period October 1, 2019 to September
               30, 2020, and their auditors who audit and report on such user entities’ financial statements or internal
               control over financial reporting and have a sufficient understanding to consider it, along with other
               information, including information about controls implemented by subservice organizations of the system
               themselves, when assessing the risks of material misstatement of user entities’ financial statements.

               MassMutual uses the subservice organizations identified in Section III to perform some of the services
               provided to user entities that are likely to be relevant to those user entities’ internal control over financial
               reporting. The description includes only the control objectives and related controls of MassMutual and
               excludes the control objectives and related controls of the subservice organizations. The description also
               indicates that certain control objectives specified in the description can be achieved only if
               complementary subservice organization controls assumed in the design of our controls are suitably
               designed and operating effectively along with the related controls at MassMutual. The description does
               not extend to controls of the subservice organizations.

               We confirm, to the best of our knowledge and belief, that:
               a) The  description  fairly  presents  the  Defined  Benefit  and  Defined  Contribution  Investment  Service
                  Operations System made available to user entities of the system during some or all of the period October
                  1, 2019 to September 30, 2020 for processing their transactions as it relates to controls that are likely
                  to be relevant to user entities’ internal control over financial reporting. The criteria we used in making
                  this assertion were that the description

                         i.   presents how the system made available to user entities of the system was designed and
                              implemented to process relevant user entity transactions, including, if applicable,

                              (1) the types of services provided, including, as appropriate, the classes of transactions
                                 processed;

                              (2) the procedures, within both automated and manual systems, by which those services
                                 are provided, including, as appropriate, procedures by which transactions are initiated,
                                 authorized,  recorded,  processed,  corrected  as  necessary,  and  transferred  to  the
                                 reports and other information prepared for user entities of the system;

                              (3) the information  used in the performance of the procedures, including,  if applicable,
                                 related accounting records, whether electronic or manual, and supporting information
                                 involved  in  initiating,  authorizing, recording,  processing, and  reporting  transactions;
                                 this includes the correction of incorrect information and how information is transferred
                                 to the reports and other information prepared for user entities;

                              (4) how the system captures and addresses significant events and conditions other than
                                 transactions;
                Massachusetts Mutual Life Insurance Company (MassMutual®), Springfield, MA 01111, and its affiliated Companies.

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