ARRANGE 9 wafers on bottom of 9-inch square pan; set aside. Beat pudding mix and milk in medium bowl with whisk 2 min. Let stand 5 min. Stir in Cool Whip.
SPREAD half the pudding mixture over wafers in pan; top with layers of 9 of the remaining wafers and remaining pudding mixture. Cover with remaining wafers.
REFRIGERATE 3 hours. Spread with frosting just before serving.
serving size = 1 square (70 g)
