Page 54 - NovDefComp

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 Recordkeeping Operations System entitled,
“Description of the Defined Benefit and Defined Contribution Recordkeeping 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 and user
entities 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.

The description indicates that certain control objectives specified in the description can be achieved only
if complementary user entity controls assumed in the design of MassMutual’s controls are suitably
designed and operating effectively, along with related controls at MassMutual. The description does not
extend to controls of the user entities.

We confirm, to the best of our knowledge and belief, that:

a) The description fairly presents the Defined Benefit and Defined Contribution Recordkeeping 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
Massachusetts Mutual Life Insurance Company (MassMutual®), Springfield, MA 01111, and its affiliated Companies.

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