CHOP 4 wafers; set aside. Arrange 12 wafers on bottom of 9x5-inch loaf pan lined with foil.
BEAT pudding mixes and milk with whisk 2 min. Add COOL WHIP; spoon 1/3 over wafers in pan. Top with 12 wafers and 2 Tbsp. caramel topping. Repeat layers of pudding mixture, wafers and caramel topping. Cover with remaining pudding mixture. Sprinkle with chopped wafers; press gently into pudding mixture.
FREEZE 4 hours or until firm. Lift dessert from pan, using foil handles. Place on serving plate. Let stand 15 min. to soften slightly before serving.