Merrill Lynch & Co., Inc.

October 17, 2002

Ms. Jennifer J. Johnson
Secretary, Board of Governors of the
Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551

Office of the Comptroller of the Currency
250 E Street, SW
Public Information Room
Mail Stop 1-5
Washington, DC 20219
Attention: Docket No. 02-13


Mr. Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 5th Street, NW
Washington, DC 20549-0609

Elizabeth McCaul
Superintendent, New York State Banking Department
2 Rector St.
New York, NY 10006-1894

Re: Response to Draft Interagency White Paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System;

    Board of Governors of the Federal Reserve System: Docket No. R-1128

    Office of the Comptroller of the Currency: Docket No. 02-13

    Securities and Exchange Commission: File No. S7-32-02

Dear Sirs and Mesdames:

We submit this response to the Draft Interagency White Paper on Sound Practices to Strengthen the Resilience of the U.S. Financial System, published in the Federal Register by the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "White Paper"). We have also submitted a joint response to the White Paper with several other large securities firms. The purpose of this letter is to inform you that we have read the response to the White Paper submitted by the Securities Industry Association and Bond Market Association and concur with the issues raised and positions espoused in that letter. Please feel free to call either of the undersigned if you have any questions.

Very truly yours,

John A. McKinley
Executive Vice President & Head of Global Technology & Services,
Merrill Lynch & Co., Inc.

John W. Cummings
Senior Vice President & Chief Operating Officer of Global Technology & Services, Merrill Lynch & Co., Inc.