COMERICA INC — Director's Dealing 2004

Nov 30, 2004

SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-11-23

Reporting Person: Beck Mary Constance (EVP-Small Bus/Pers Fin Svc)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	10405	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$60.7	2014-11-03	Common Stock (30000)		Direct

Footnotes

F1: This number includes shares acquired through employee stock plans as of November 23, 2004.

F2: The options vest in four equal annual installments beginning on the date indicated in this column.