Preheat oven to 350. Finely crush 40 of the wafers; place in medium bowl.
Add butter and sugar; mix until well blended. Press firmly onto bottom of 13x9-inch baking pan.
Bake 8 min. or until lightly browned; set aside.
In a bowl combine 1-1/4 cups of the milk and the dry chocolate pudding mix.
Beat with wire whisk 2 min. or until well blended. Spread over crust; top with remaining 24 wafers.
Pour remaining 2 cups milk into large bowl. Add dry white chocolate or vanilla pudding mixes.
Beat with wire whisk 2 min. or until well blended. Gently stir in whipped topping. Spread over wafer layer in pan.
Refrigerate at least 3 hours or until set.
Preheat broiler just before serving. Top dessert evenly with marshmallows.
Broil 1 min. or until marshmallows are puffed and lightly browned. Sprinkle with chocolate.
Cut into 24 squares. Serve immediately. Serves 24