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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
                                   Defined Benefit and Defined Contribution

                                       Recordkeeping Operations System



                   External
                  Subservice      Services Provided         Related Control      Complementary Subservice
                                                              Objectives
                                                                                    Organization Controls
                 Organization
                Matrix         Matrix Trust Company     Control Objective 1,    Matrix should have controls
                               is used for trust and    DB Plan Administration:   in place to ensure plan
                               investment services and   Plan Installation      setup, distributions and
                               is fully integrated with   Control Objective 4,  payments, contributions and
                               the MassMutual                                   collections and plan
                               systems for newly        DC and DB Plan          investment transfers are
                                                        Administration:
                               onboarded Qualified &                            authorized processed
                               Non-Qualified DB plans.  Investment Asset        completely, accurately and
                                                        Valuation
                                                                                timely. Additionally, they
                                                        Control Objective 6,    should have controls in place
                                                        DB Plan Administration:   over completeness and
                                                        Distributions and       accuracy of trading and
                                                        Payments                settlement transactions.
                                                        Control Objective 7,
                                                        DB Plan Administration:
                                                        Contributions
                                                        Control Objective 8,
                                                        DB Plan Administration:
                                                        Transfers



               All  third  party  subservice  organizations  contracted  by  MassMutual  undergo  stringent  review  prior  to
               acceptance. Additionally, MassMutual obtains SOC 1 reports as available from subservice organizations
                                                               ®
               which are reviewed for control weaknesses that could potentially impact MassMutual’s business processing
               and  to  identify  any  ‘complementary  user  entity’  controls  identified  by  the  subservice  providers  that
               MassMutual may need to address to help ensure the successful achievement of the subservice provider’s
               control objectives.
                                                                                 ®
               Where  SOC  1 or  similar  attestations  are  not  available,  or  the  SOC  1 provided  does  not  cover  the
                             ®
               operations pertinent to MassMutual, MassMutual conducts appropriate periodic quality and due diligence
               procedures.
               Enterprise Technology and Experience (ETX) organization provides the General Information Technology
               Controls (GITC) system in support of the DB and DC recordkeeping systems used to support MassMutual
               business operations.  ETX should  have controls  over: documenting,  authorizing,  testing,  approving and
               implementing application changes; documenting, authorizing, testing, approving and implementing system
               software  changes;  physical  security  and  environmental  protection  of  computer  equipment  and  storage
               media; provisioning, termination, and recertification of user access based upon job responsibilities;; the
               scheduling of production processing and system backups, and the identification and resolution of deviations
               from the schedule; and the completion and security of data transmissions, and identification and resolution
               of failures. While these GITCs are not addressed in this report, they may be found in the “Defined Benefit
               and  Defined  Contribution  Recordkeeping  Operations  General  Information  Technology  Controls System
               SOC  1 Report”  for  the  period  October  1,  2019 through  September  30,  2020 which  is  available  from
                      ®
               MassMutual. All control objectives in this report rely on ETX as a subservice provider as the application
               controls within the business processes rely upon an effective GITC environment.



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