COMERICA INC — Director's Dealing 2004

Nov 9, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-11-05

Reporting Person: BERAN JOHN R (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-11-05	Common Stock	M	2500	$25.42	Acquired	45089	Direct
2004-11-08	Common Stock	S	2500	$62.62	Disposed	42589	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-11-05	Employee Stock Option (right to buy)	$25.42	M	2500	Disposed	2006-04-14	Common Stock (6800)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1025	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$40.25	2007-04-20	Common Stock (16500)	16500	Direct
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (15000)	15000	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (20000)	20000	Direct
Employee Stock Option (right to buy)	$41.5	2010-03-17	Common Stock (17400)	17400	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (15800)	15800	Direct
Employee Stock Option (right to buy)	$63.2	2012-04-17	Common Stock (26000)	26000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (35000)	35000	Direct
Employee Stock Option (right to buy)	$52.5	2014-04-16	Common Stock (40000)	40000	Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of October 1, 2004.

F2: As of October 1, 2004.

F3: The options vest in four equal annual installments beginning on the date indicated in this column.