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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                        Defined Benefit and Defined Contribution Recordkeeping

                                    Investment Service Operations System

               Control Objectives, Related Controls, and Tests of Operating
               Effectiveness

               MassMutual has specified  its control objectives and identified the controls to achieve these  objectives.
               These objectives have been determined by management of the Company by reference to, among other
               information sources, the AICPA Audit and Accounting Guide for Employee Benefit Plans.
               MassMutual control objectives and related controls are included in Section IV of this report “MassMutual’s
               Control Objectives and Related  Controls, and  KPMG LLP's Tests Of Controls  And Results of Tests of
               Operating Effectiveness" and are an integral part of MassMutual's system description.

               The Service Auditor has determined  the nature,  timing, and  extent  of  testing  to be  performed. Further
               information on the nature, timing, and extent of testing and results of testing is contained in Section IV.

























































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