Page 22 - NovDefComp
P. 22

MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                        Defined Benefit and Defined Contribution Recordkeeping

                                    Investment Service Operations System

               Complementary Subservice Organization Controls (CSOCs)

               MassMutual’s  systems  and  the  controls  over  Investment  Service  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 internal controls by subservice organizations is necessary to achieve
               certain  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.

                   External
                  Subservice      Services Provided         Related Control      Complementary Subservice
                                                              Objectives
                                                                                    Organization Controls
                 Organization
                SSC            State Street             Control Objective 1,    State Street Corporation
                               Corporation (SSC) is     Pricing                 (SSC) should have controls
                               used for pricing                                 in place to ensure that Unit
                               calculations for portfolio                       Values are calculated
                               investment accounts.                             accurately and transmitted to
                                                                                MassMutual completely,
                                                                                accurately and timely. Any
                                                                                discrepancies should be
                                                                                researched and resolved
                                                                                timely.

                RTC            Reliance Trust (RTC)     Control Objective 1,    Reliance Trust (RTC)
                               is used for pricing                              should have controls in place
                               calculations for unitized   Pricing              to ensure unit values are
                               plans’ customized                                accurately calculated for plan
                               investments.                                     level unitized accounts which
                                                                                include, but not limited to,
                                                                                collective trusts and
                                                                                company stock prices.
                                                                                Additionally, RTC should
                                                                                have controls to ensure
                                                                                these prices transmitted to
                                                                                MassMutual completely,
                                                                                accurately, and timely. Any
                                                                                discrepancies should be
                                                                                researched and resolved
                                                                                timely.



               All  third  party  subservice  organizations  contracted  by  MassMutual  undergo  stringent  review  prior  to
               acceptance. Additionally, MassMutual obtains SOC 1 reports as available from subservice organizations
                                                               ®
               which are reviewed for control weaknesses that could potentially impact MassMutual’s business processing
               and  to  identify  any  ‘complementary  user  entity’  controls  identified  by  the  subservice  providers  that
               MassMutual  may  need  to  address  to  help  ensure  the  successful  achievement  of  the  subservice
               organization’s control objectives.



                MassMutual Defined Benefit and Defined                    Description of the System Provided by
                Contribution Investment Service Operations                                       MassMutual
                System
                                                             11
   17   18   19   20   21   22   23   24   25   26   27