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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                        Defined Benefit and Defined Contribution Recordkeeping

                                    Investment Service Operations System

               Additionally, plans may invest in SIAs that invest in various other investments managed by certain affiliated
               and unaffiliated advisors. These investments include public and private stock funds, mutual funds, common
               collective trusts, real estate investment trusts, separate accounts, asset allocation funds, and individually
               managed accounts. The transaction processing and other administrative services for these investments
               are performed by the respective fund management company.
               For  DC  customers  that  hold  direct  investments  in  mutual  funds  and/or  CITs,  mutual  fund  and  CIT
               transactions are processed by a custodian through the National Securities Clearing Corporation (NSCC).
               Direct mutual fund and/or CIT investments are managed by a wide variety of asset managers from across
               the industry.
               MMRS also has an alliance in place with Schwab, a registered broker-dealer and a member of the FINRA
               and the Securities Investor Protection Corporation (SIPC). Schwab is a provider of brokerage services to
               retirement plans and is also the broker for many of the country’s mutual funds and corporate investors.
               Schwab provides Self-Directed Brokerage Account (SDBA) services to MMRS plans with assets over $1
               million. The SDBA provides participants additional investment flexibility by giving them access to over 6,500
               mutual funds managed by more than 300 fund families, as well as individual stock and bond investments.
               Schwab provides investors in the SDBA with mutual fund prospectuses, quotes, and daily account trading.
               Investors also receive a written confirmation of each trade, monthly activity statements (for active accounts)
               or quarterly statements (for inactive accounts). Schwab trades can be made via telephone or through the
               Internet using Schwab’s “PCRA On-Line Trading” application. After receiving an application from MMRS,
               participants set up their accounts through Schwab.

               Defined Contributions – Investment Only products (DC-IO) are products in which MassMutual manages the
               investments but does not provide the recordkeeping at the participant level. State Street Bank in Kansas
               City provides the fund accounting. Trades are transmitted either via FAX/e-mail or through the NSCC. State
               Street Bank in Boston acts as the Custodian for these funds.
               Stable value investment products – With the exception of Stable Return (Wells/Galliard) – MM affiliate,
               Barings, provides asset management oversight for stable value investment products. Descriptions of these
               products are available in documents pertaining to the individual stable value products, all of which are
               included in an annual 5500 package submitted to participants.

               Pricing
               SIAs and direct investments in mutual funds and/or CITs are valued on a daily basis. MMRS receives daily
               distribution rates, mutual fund NAVs, and in some cases the related change from the prior day rate or NAV
               from  the  SSC, NSCC,  Vertical  Management  Services (VMS),  and  other  mutual  fund  management
               companies. Valuation procedures are performed once the mutual fund prices (NAVs and distribution rates)
               are received. All newly onboarded DB full service plans are handled by Matrix Trust Company.

               Pooled SIAs are valued on the Unival system within MassMutual. The valuation of the asset allocation SIAs
               on Unival is based on the value of the mutual fund shares held in the separate account and are divided by
               the units held to calculate a unit value price. The valuation of the non-asset allocation SIA’s on Unival use
               the Net Investment Factor (NIF) formula. Plans and participants own units of the SIA.
               Prior to calculating daily unit values for pooled SIAs, Unival performs edit checks of underlying tables within
               the Unival application to the previous day’s tables and reports and resolves all unanticipated changes.
               Investment operations associates review the reported changes and investigate any unanticipated changes.
               Unival receives daily distribution rates, mutual fund NAVs, and in some cases the related change from the
               prior day’s rate or NAV from the RTC, SSC, NSCC, VMS and other mutual fund management companies.
               Unival also provides the ability to enter valuation information manually. Unival requires entry of the current
               day NAV and the change from the prior day, as well as the current day dividend rate and the change from
               the prior day dividend rate, before transmitting unit values to CaRS.


                MassMutual Defined Benefit and Defined                    Description of the System Provided by
                Contribution Investment Service Operations                                       MassMutual
                System
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