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.