COMERICA INC — Director's Dealing 2004

Apr 20, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-04-16

Reporting Person: LAKE JAMES E (SVP/Dir. of Human Resources)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-04-16	Common Stock	A	2000	—	Acquired	10089	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-04-16	Employee Stock Option (right to buy)	$52.5	A	5000	Acquired	2014-04-16	Common Stock (5000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	3418	Indirect
Common Stock	18	Indirect
Common Stock	13	Indirect
Common Stock	17	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (3325)	3325	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (3650)	3650	Direct
Employee Stock Option (right to buy)	$41.5	2010-03-17	Common Stock (3775)	3775	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (3350)	3350	Direct
Employee Stock Option (right to buy)	$63.2	2012-04-17	Common Stock (4600)	4600	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (4500)	4500	Direct

Footnotes

F2: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of March 12, 2004.

F3: As of March 12, 2004.

F4: The options vest in four equal annual installments beginning on the date indicated in this column.