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Gary
Carlin
Managing
Director
Corporate Controller
(212)
449-5825
Gary_Carlin@ml.com
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4 World Financial Center
New
York, New
York 10080
January
17, 2008
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Mr.
Rufus
Decker
Accounting
Branch Chief
Securities
and Exchange Commission
Division
of Corporation Finance
100
F
Street, NE
Washington,
DC 20549-7010
Re: Merrill
Lynch & Co., Inc. (“Merrill Lynch”)
Commission
File No. 1-7182
Dear
Mr.
Decker,
Merrill
Lynch is in receipt of your letter of December 28, 2007, concerning the staff’s
review of Merrill Lynch’s report on Form 10-K for the fiscal year ended December
29, 2006 and Forms 10-Q for the fiscal quarters ended March 30, 2007, June
29,
2007 and September 28, 2007. Further to a telephone conversation
between Gus Rodriguez of the SEC and David Moser of Merrill Lynch, on January
15, 2008, this is to advise you that the staff’s comments are under active
consideration and that Merrill Lynch intends to provide comprehensive responses
at the earliest practicable date. Due to staffing commitments
necessary for preparation of our full year 2007 earnings announcement on January
17, 2008, we believe that we will be in a position to respond to the comment
letter by January 31, 2008.
Thank
you
for your attention.
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Sincerely, |
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/s/
Gary
Carlin |
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Gary
Carlin |
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Managing
Director |
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Corporate
Controller |
CC:
N. Chai
C.
Hayward
D.
Moser