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MassMutual Retirement Services Fund Exchange Policy for Retirement Plans Investing in Funds through Custodial Accounts with Recordkeeping Services from MassMutual Retirement Services

What is a Fund exchange? A “Fund exchange” is a transaction requested by you that involves reallocating part or all of your Participant Account value among the mutual funds or collective investment trusts (“Funds”) available in your plan. What restrictions are there on your ability to make a Fund exchange? First, you may make only one Fund exchange request each day. We limit each Participant to one Fund exchange request each day the New York Exchange is open for trading (“Business Day”). We count all Fund exchange activity that occurs on any one Business Day as one “Fund exchange”, however, you cannot transfer the same Participant Account value more than once a Business Day. For example: Massachusetts Mutual Life Insurance Company • If the only exchange you make on a day is a transfer of $10,000 from one Fund into another Fund, it and affiliates, Springfield, MA 01111-0001 Massachusetts Mutual Life Insurance Company and affiliates, Springfield, MA 01111-0001 would count as one Fund transfer. www.massmutual.com Massachusetts Mutual Life Insurance Company www.massmutual.com • andIf, affiliates, however, Springfield, on aMA single 01111-0001 day you transfer $10,000 out of one Fund into five other Funds (dividing the www.massmutual.com$10,000 among the five other Funds however you chose), that day’s transfer activity would count as one Fund exchange. • Likewise, if on a single day you transferred $10,000 out of one Fund into ten other Funds (dividing the $10,000 among the ten other Funds however you chose), that day’s transfer activity would count as one Fund exchange. • Conversely, if you have $10,000 in Participant Account value distributed among 10 different Funds and you request to transfer the Participant Account value in all those Funds into one Fund, that would also count as one Fund exchange. • However, you cannot transfer the same Participant Account value more than once in one day. That means if you have $10,000 in a and you transfer all $10,000 into a stock , on that same day you could not then transfer the $10,000 out of the stock fund into another Fund. Second, you are allowed to submit a total of 20 Fund exchanges each Calendar Year (the “Transfer Rule”) by the Retirement Plan Information Line telephone system, Retirement Access Internet applica- tion or US mail. Once you have reached the maximum number of Fund exchanges, you may only submit any additional Fund exchange requests and any trade cancellation requests in writing through U.S. Mail or overnight delivery service. In other words, internet or telephone exchange requests will Massachusetts Mutual Life Insurance Company and affiliates not be honored. We may, but are not obligated to, notify you when you are in jeopardy of approaching 1295 State Street, Springfield, MA 01111-0001 Massachusetts Mutual Life Insurance Company and affiliates 1295 State Street, Springfield, MA 01111-0001 these limits. For example, we will send you a letter after your 10th Fund exchange to remind you about Massachusettsthis Mutual limitation. Life Insurance After Company your and 20th affiliates Fund exchange, we set our computer system so that it will not allow you 1295 State Street, Springfield, MA 01111-0001 to do another Fund exchange by Retirement Plan Information Line or via the internet. You will then be instructed to send your Fund exchange request by U.S. Mail or overnight delivery service. The Transfer Rule does not apply to Fund exchanges that occur automatically as part of an or program that operates pursuant to our recordkeeping system. Reallocations made based on a Fund merger or liquidation also do not count toward this transfer limit. Additionally, changes your plan sponsor or other plan fiduciary make to your plan’s Fund line-up do not count towards this transfer limit either. We make no assurances that the Transfer Rule is or will be effective in detecting or preventing . The Transfer Rule applies only to Participants in plans where the employer-plan sponsor has agreed to it under a recordkeeping service agreement with us. In some cases, plans that have older recordkeep- ing service agreements, or do not have a direct recordkeeping service agreement with us, are not subject to the Transfer Rule. In addition, Participants in several hundred of the plans that we provide services to under service contracts that we acquired from the Princeton Retirement Group are not subject to the Transfer Rule. Some, or all, of these plan sponsors may refuse to agree to the Transfer Rule. Participants in such plans may be subject to only limited recordkeeping platform-level trading restrictions or no recordkeeping platform-level trading restrictions at all. We may make changes to this policy under our recordkeeping services agreement with the employer- plan sponsor at any time upon forty-five (45) days written notice to the employer. Third, Fund policies have been designed to restrict excessive Fund exchanges and trading activity. The Funds available as investment options under your plan are intended to be -term investments, and are not intended as -term trading vehicles. Frequent or excessive trading activity or “market timing” in the Funds by shareholders (which includes frequent transfer activity into and out of the same Fund, or frequent Fund exchanges in order to exploit any inefficiencies in the pricing of a Fund) can negatively impact the costs and returns of the Funds, which affect all shareholders. As a result, most Funds have their own specific policies on frequent trading and exchanges. In some cases, the Fund family may direct us to restrict your ability to place Fund exchanges or purchases in their Funds if they discover that you have violated their policies. Frequent trading policies for individual Funds can be found in the Fund’s prospectus. Even if you do not engage in market timing, certain restrictions may be imposed on you, as discussed below: Fund Trading Policies: Generally, you are subject to Fund trading policies, if any. We are obligated to provide, at the Fund’s request, tax identification numbers and other shareholder identifying information contained in our records to assist Funds in identifying any pattern or frequency of Fund exchanges that may violate their trading policy. In certain instances, we have agreed to serve as a Fund’s agent to help monitor compli- ance with that Fund’s trading policy. We are obligated to follow each Fund’s instructions regarding enforcement of their trading policy. Penalties for violating these policies may include, among other things, temporarily or permanently limiting or banning Fund transfers into a Fund or other funds within that Fund complex. We are not authorized to grant exceptions to a Fund’s trading policy. Please refer to each Fund’s prospectus for more information. Transactions that cannot be processed because of Fund instructions regarding Fund trading policies will be considered not in good order.

© 2013 Massachusetts Mutual Life Insurance Company, Springfield, MA 01111-0001. All rights reserved. www.massmutual.com. MassMutual Financial Group is a marketing name for Massachusetts Mutual Life Insurance Company (MassMutual) [of which Retirement Services is a division] and its affiliated companies and sales representatives. RS2436 713