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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;
(5) the process used to prepare reports and other information for user entities;

(6) services performed by a subservice organization, if any, including whether the carve-
out method or the inclusive method has been used in relation to them;

(7) the specified control objectives and controls designed to achieve those objectives,
including, as applicable, complementary user entity controls and complementary
subservice organization controls assumed in the design of the service organization’s
controls;

(8) other aspects of our control environment, risk assessment process, information and
communications (including the related business processes), control activities and
monitoring activities that are relevant to the services provided.

ii. includes relevant details of changes to MassMutual’s system during the period covered by
the description.

iii. does not omit or distort information relevant to MassMutual’s system, while acknowledging
that the description is prepared to meet the common needs of a broad range of user entities
of the system and their auditors, and may not, therefore, include every aspect of the
Defined Benefit and Defined Contribution Recordkeeping Operations System that each
individual user entity of the system and its auditor may consider important in its own
particular environment.

b) The controls related to the control objectives stated in the description were suitably designed and
operating effectively throughout the period October 1, 2019 to September 30, 2020 to achieve those
control objectives if subservice organizations and user entities applied the complementary controls
assumed in the design of MassMutual’s controls throughout the period October 1, 2019 to September
30, 2020. The criteria we used in making this assertion were that:

i. the risks that threaten the achievement of the control objectives stated in the description
have been identified by management of MassMutual;
ii. the controls identified in the description would, if operating effectively, provide reasonable
assurance that those risks would not prevent the control objectives stated in the description
from being achieved; and

iii. the controls were consistently applied as designed, including whether manual controls
were applied by individuals who have the appropriate competence and authority.

Massachusetts Mutual Life Insurance Company

Massachusetts Mutual Life Insurance Company (MassMutual®), Springfield, MA 01111, and its affiliated Companies.

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