SEC FORM 3

SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0104
Estimated average burden
hours per response:			0.5

1. Name and Address of Reporting Person^*

Edwards Jeffrey N

(Last)

(First)

(Middle)

MERRILL LYNCH & CO., INC.

4 WORLD FINANCIAL CENTER

(Street)

NEW YORK

10080

(City)

(State)

(Zip)

2. Date of Event Requiring Statement (Month/Day/Year)
03/31/2005

3. Issuer Name and Ticker or Trading Symbol
MERRILL LYNCH & CO INC [ MER ]

4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director	10% Owner
X	Officer (give title below)	Other (specify below)
	Chief Financial Officer

5. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)
Common Stock	230,098⁽¹⁾	D

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
1. Title of Derivative Security (Instr. 4)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
Stock Option - Right to Acquire⁽²⁾	⁽³⁾	01/25/2009	Common Stock	5,786	$36.1719	D
Stock Option - Right to Acquire⁽²⁾	⁽⁴⁾	01/25/2009	Common Stock	22,416	$36.1719	D
Stock Option - Right to Acquire⁽²⁾	⁽⁵⁾	01/27/2010	Common Stock	54,950	$43.7812	D
Stock Option - Right to Acquire⁽²⁾	⁽⁶⁾	01/23/2011	Common Stock	57,245	$77.5625	D
Stock Option - Right to Acquire⁽²⁾	⁽⁷⁾	01/28/2012	Common Stock	110,990	$53.745	D
Stock Option - Right to Acquire⁽²⁾	⁽⁸⁾	01/27/2013	Common Stock	58,228	$36.065	D
Stock Option - Right to Acquire⁽²⁾	⁽⁹⁾	01/26/2014	Common Stock	33,088	$59.85	D

Explanation of Responses:

1. This total includes 89,407 Restricted Shares granted under the Merrill Lynch & Co., Inc. Long-Term Incentive Compensation Plan and 67,411 Restricted Shares granted under the Merrill Lynch & Co., Inc. Employee Stock Compensation Plan. These shares are subject to vesting and restricted periods. Transactions under these plans are exempt under the provisions of Rule 16b-3.

2. These stock options were granted under the Merrill Lynch & Co., Inc. Long-Term Incentive Compensation Plan (the "Plan"). Transactions under this Plan are exempt under the provisions of Rule 16b-3.

3. All stock options became exercisable after 1/25/2004.

4. All stock options became exercisable on 1/25/2001.

5. 10,990 stock options became exercisable after each of 1/27/2001, 1/27/2002, 1/27/2003, 1/27/2004 and 1/27/2005.

6. All stock options became exercisable after 7/31/2001.

7. All stock options became exercisable after 7/31/2002.

8. 14,557 stock options became exercisable after each of 1/27/2004 and 1/27/2005. 14,557 stock options will become exercisable after each of 1/27/2006 and 1/27/2007.

9. 8,272 stock options became exercisable after 1/26/2005. 8,272 stock options will become exercisable after each of 1/26/2006, 1/26/2007 and 1/26/2008.

Remarks:

All reported positions have been rounded down to the nearest whole number.

	Jeffrey N. Edwards (by Michael A. LaMaina, as agent)	04/08/2005
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.