As Of                Filer                Filing    For·On·As Docs:Size              Issuer               Agent

 8/05/05  Merrill Lynch & Co., Inc.         10-Q        7/01/05   10:907K                                   RR Donnelley/FA

Document/Exhibit                   Description                      Pages   Size 

 1: 10-Q        Merrill Lynch & Co., Inc.                           HTML    612K 
 2: EX-3        Ex-3: By-Laws                                       HTML    124K 
 3: EX-12       Ex-12: Statement Re: Computation of Ratios          HTML     17K 
 4: EX-15       Ex 15: Letter Re: Unaudited Interim Financial       HTML     24K 
                          Information                                            
 5: EX-18       Ex-18: Letter Re: Change in Accounting Principle    HTML     10K 
 6: EX-31.1     Ex-31.1: Certification                              HTML     12K 
 7: EX-31.2     Ex-31.2: Certification                              HTML     12K 
 8: EX-32.1     Ex-32.1: Certification                              HTML      9K 
 9: EX-32.2     Ex-32.2: Certification                              HTML      9K 
10: EX-99       Ex-99: Charter of the Nominating and Corporate      HTML     22K 
                          Goverance Committee                                    

Exhibit 18

To the Board of Directors and Stockholders of Merrill Lynch & Co., Inc.:

At your request, we have read the description included in your Quarterly Report on Form 10-Q to the Securities and Exchange Commission for the quarter ended July 1, 2005, of the facts relating to a change in accounting principle that results in the presentation of cash collateral related to derivatives contracts on a net basis. The accounting for credit support agreements related to derivative contracts is being changed from the presentation of cash collateral pledged and received as separate assets and liabilities to the presentation of cash collateral on a net basis with the value of the related derivatives in your consolidated financial statements. This is a more relevant presentation of the credit risk of the associated derivative contracts. We believe, on the basis of the facts so set forth and other information furnished to us by appropriate officials of Merrill Lynch & Co., Inc. and subsidiaries (“Merrill Lynch”), that the accounting change described in your Form 10-Q is to an alternative accounting principle that is preferable under the circumstances.

We have not audited any consolidated financial statements of Merrill Lynch as of any date or for any period subsequent to December 31, 2004. Therefore, we are unable to express, and we do not express, an opinion on the facts set forth in the above mentioned Form 10-Q, on the related information furnished to us by officials of Merrill Lynch, or on the financial position, results of operations, or cash flows of Merrill Lynch as of any date or for any period subsequent to December 31, 2004.

Yours truly,
/s/ Deloitte & Touche LLP

New York, New York
August 5, 2005