<DOCUMENT>
<TYPE>EX-99.77B
<SEQUENCE>2
<FILENAME>exh-77b_15728.txt
<DESCRIPTION>ACCOUNTANT'S REPORT ON INTERNAL CONTROLS
<TEXT>
                                                                   EXHIBIT 77(B)
                                                                   -------------

[KPMG LOGO]     KPMG LLP                             Telephone   617 988  1000
                99 High Street                       Fax         617 507  8321
                Boston, MA 02110-2371                Internet    WWW.US.KPMG.COM
                                                                 ---------------



             Report of Independent Registered Public Accounting Firm

The Shareholders and Board of Trustees of MassMutual Participation Investors

In planning and performing our audit of the financial statements of MassMutual
Participation Investors (the "Company") as of and for the year ended December
31, 2007, in accordance with the standards of the Public Company Accounting
Oversight Board (United States), we considered the Company's internal control
over financial reporting, including controls over safeguarding securities, as a
basis for designing our auditing procedures for the purpose of expressing our
opinion on the financial statements and to comply with the requirements of Form
N-SAR, but not for the purpose of expressing an opinion on the effectiveness of
the Company's internal control over financial reporting. Accordingly, we express
no such opinion.

Management of the Company is responsible for establishing and maintaining
effective internal control over financial reporting. In fulfilling this
responsibility, estimates and judgments by management are required to assess the
expected benefits and related costs of controls. A company's internal control
over financial reporting is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with generally accepted
accounting principles. A company's internal control over financial reporting
includes those policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect the
transactions and dispositions of the assets of the company; (2) provide
reasonable assurance that transactions are recorded as necessary to permit
preparation of financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the company are
being made only in accordance with authorizations of management and directors of
the company; and (3) provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of the company's
assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting
may not prevent or detect misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that controls may become
inadequate because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists when the design
or operation of a control does not allow management or employees, in the normal
course of performing their assigned functions, to prevent or detect
misstatements on a timely basis. A material weakness is a deficiency, or a
combination of deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material misstatement of the
Company's annual or interim financial statements will not be prevented or
detected on a timely basis.



           KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative.
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[KPMG LOGO]



Our consideration of the Company's internal control over financial reporting was
for the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control that might be material
weaknesses under standards established by the Public Company Accounting
Oversight Board (United States). However, we noted no deficiencies in the
Company's internal control over financial reporting and its operation, including
controls over safeguarding securities, that we consider to be a material
weakness as defined above as of December 31, 2007.

This report is intended solely for the information and use of management and the
Company and the Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.

                                       /s/ KPMG LLP

February 11, 2008
<PAGE>
[KPMG LOGO]     KPMG LLP                             Telephone   617 988  1000
                99 High Street                       Fax         617 507  8321
                Boston, MA 02110-2371                Internet    WWW.US.KPMG.COM
                                                                 ---------------



            Report of Independent Registered Public Accounting Firm

The Shareholders and Board of Trustees of MassMutual Participation Investors

We have audited the accompanying statement of assets and liabilities of
MassMutual Participation Investors (the Trust), including the schedule of
investments, as of December 31, 2007, and the related statements of operations
and cash flows for the year then ended and the statements of changes in net
assets for each of the years in the two-year period then ended and the financial
highlights for each of the years in the four-year period then ended. These
financial statements and financial highlights are the responsibility of the
Trust's management. Our responsibility is to express an opinion on these
financial statements and financial highlights based on our audits. The financial
highlights for the year ended December 31, 2003 was audited by other independent
registered public accountants whose report, dated February 6, 2004, expressed an
unqualified opinion on those financial highlights.

We conducted our audits in accordance with the standards of the Public Company
Accounting Oversight Board (United States). Those standards require that we plan
and perform the audit to obtain reasonable assurance about whether the financial
statements and financial highlights are free of material misstatement. An audit
includes examining, on a test basis, evidence supporting the amounts and
disclosures in the financial statements. Our procedures included confirmation of
securities owned as of December 31, 2007 by counting securities at the custodian
and by correspondence with the custodian, or by other appropriate auditing
procedures. An audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audits provide a
reasonable basis for our opinion.

In our opinion, the financial statements and financial highlights referred to
above present fairly, in all material respects, the financial position of
MassMutual Participation Investors as of December 31, 2007, and the results of
its operations, its cash flows, the changes in its net assets, and the financial
highlights for the years described above, in conformity with accounting
principles generally accepted in the United States of America.

                                       /s/ KPMG LLP
Boston, Massachusetts
February 11, 2008





           KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative.
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