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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                                   Defined Benefit and Defined Contribution

                                       Recordkeeping Operations System



               Complementary Subservice Organization Controls (CSOCs)
               MassMutual’s systems and the controls over DB and DC Recordkeeping 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 CSOCs by subservice organizations support the achievement of
               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
                                                                                    Organization Controls
                                                              Objectives
                 Organization
                DST            DST Systems (DST)        Control Objective 2,    DST should have controls in
                               Automated Work           DC and DB Plan          place to ensure scanned
                               Distributor (AWD)        Administration:         batches are transferred into
                               Document Image           Participant Maintenance  AWD completely and
                               Handling and                                     accurately and any errors are
                               Distribution is used for   Control Objective 5,  researched and resolved for
                                                        DC Plan Administration:
                               the scanning of                                  timely electronic delivery to
                               hardcopy client and      Distributions and       MassMutual.
                                                        Payments
                               participant MassMutual
                               documents mailed to a    Control Objective 6,
                               MassMutual address at    DB Plan Administration:
                               DST’s headquarters to    Distributions and
                               create electronic        Payments
                               versions for electronic
                               distribution to          Control Objective 7,
                               MassMutual Operations    DB Plan Administration:
                               staff for processing.    Distributions and
                                                        Payments
                SE2            Effective 10/1/2019 to   Control Objective 6,    SE2 should have controls in
                               12/19/2019 SE2 was       DB Plan Administration:   place to ensure payments to
                               used to process and      Distributions and       participants are authorized
                               administer participant   Payments                and processed completely,
                               lump sum and repetitive                          accurately, and timely.
                               payments for a limited
                               number of DB plans.

















                MassMutual Defined Benefit and Defined                    Description of the System Provided by
                Contribution Recordkeeping Operations System                                     MassMutual
                                                             11
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