Reserve 16 wafers. Finely crush remaining wafers; place in medium bowl.
Add sugar and butter; mix well. Press firmly onto bottom of 9-inch pie plate. Stand reserved wafers around edge of pie plate; set aside.
Beat pudding mixes and 1 cup milk in large bowl with whisk 2 min.
Add pumpkin and pumpkin pie spice; mix well. (
Mixture will be thick.)
Spread onto bottom of crust. Microwave marshmallows and remaining milk in large microwaveable bowl on HIGH 1-1/2 min. or until marshmallows are completely melted, stirring after 1 min. Stir until mixture is blended. Refrigerate 15 min. or until completely cooled. Gently stir in COOL WHIP; spread over pumpkin layer in crust.