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MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
Defined Benefit and Defined Contribution

Recordkeeping Operations System

Information and Communication
MassMutual management consistently and regularly communicates the importance of following policies
and procedures as well as the importance of complying with the rules and regulations that govern our
operations. Management uses a variety of mechanisms to communicate this message including department
meetings and compliance newsletters. Additionally, MassMutual Corporate Policies and Procedures help
enforce the importance of open communication channels through Corporate Policies and Procedures
Manuals such as the Code of Conduct. Associates are encouraged and empowered to identify and raise
concerns and issues to management to facilitate appropriate and timely resolution. MassMutual employs a
number of tools to facilitate open communication such as the MassMutual Compliance and Ethics Reporting
Hotline. Additionally, the employee and manager performance evaluation program is designed to
encourage open and regular communication and information sharing.

MassMutual also encourages and maintains two way communications with its Plan Sponsor and participant
clients regarding the services that MassMutual provides including new and changed products, privacy and
security concerns and satisfaction with services offered and scope and availability of related SOC reports.
Similarly, MassMutual also maintains regular two-way communication with its subservice organizations to
comment on service levels and to discuss changes in operational practices.

Other Considerations

The Company is subject to regulation and supervision by the Division of Insurance of the Commonwealth
of Massachusetts as well as other countries and states in which business is conducted. As such, the
Company is required to file periodic reports with and is subject to periodic examination by, the
Commonwealth of Massachusetts as well as other countries and states where business is. The Company’s
most recent, completed examination by the Division of Insurance was for the year ended December 31,
2014; an examination for the year ended December 31,2019 was initiated but not completed during the
period. In addition, MassMutual is subject to regulation by the Department of Labor (DOL), the Internal
Revenue Service (IRS), the Securities and Exchange Commission (SEC), and the Financial Industry
Regulatory Authority (FINRA).

Changes in the Control Environment

As part of ongoing operations, MassMutual makes changes to its operations and various support group’s
roles and responsibilities to better align the business to service clients.

The below changes to the in-scope control environment were introduced during the period:
SE2 was used to process and administer participant lump sum and repetitive payments for a
limited number of DB plans. Effective 12/20/2019 all repetitive payments are processed on PAS.

In Q1 and Q2 2020, MassMutual responded to the requirements of the CARES act passed by
congress and modified processes, where appropriate, to meet customer needs. This included the
following two control changes:

o Addition of the Legislative Control (Control 2.15)
o Modification to the loan request amount (Control 5.4)
Investment Services Operations is responsible for non-GIA pricing and trading activity. The
controls related to this have been removed from Control Objective 4 and are now in a separate
®
SOC 1, Investment Services Operations SOC 1 Report for the period October 1, 2019 through
September 30, 2020, which is also available from MassMutual.

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