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COMERICA INC Director's Dealing 2004

Mar 19, 2004

30676_dirs_2004-03-19_a33841ad-d6eb-44d5-a357-6c754455419c.zip

Director's Dealing

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SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-03-18

Reporting Person: LEWIS JOHN D (Director, Vice Chairman)

Non-Derivative Transactions

Date Security Code Shares Price A/D Holdings After Ownership
2004-03-18 Common Stock G 7500 Disposed 49230 Direct
2004-03-18 Common Stock G 7500 Acquired 70671 Indirect

Holdings (Non-Derivative)

Security Shares Ownership
Common Stock 1043 Indirect

Holdings (Derivative)

Security Exercise Price Expiration Underlying Shares Ownership
Employee Stock Option (right to buy) $18.59 2005-04-18 Common Stock (38850) 38850 Direct
Employee Stock Option (right to buy) $25.42 2006-04-14 Common Stock (37500) 37500 Direct
Employee Stock Option (right to buy) $40.25 2007-04-20 Common Stock (41250) 41250 Direct
Employee Stock Option (right to buy) $71.58 2008-03-20 Common Stock (50000) 50000 Direct
Employee Stock Option (right to buy) $66.81 2009-03-19 Common Stock (50000) 50000 Direct
Employee Stock Option (right to buy) $41.5 2010-03-17 Common Stock (75000) 75000 Direct
Employee Stock Option (right to buy) $51.43 2011-05-02 Common Stock (75000) 75000 Direct
Employee Stock Option (right to buy) $63.2 2012-04-17 Common Stock (70000) 70000 Direct
Employee Stock Option (right to buy) $40.32 2013-04-17 Common Stock (68000) 68000 Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of March 12, 2004.

F2: As of March 12, 2004.

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

F4: The insider has completed the vesting requirements for a grant of 7500 shares of stock that was previously reported in Table I as a restricted stock grant. The shares are being delivered to the insider, and the insider has elected to transfer the shares into the John D. Lewis Trust, of which the insider is the trustee and the insider's spouse is the beneficiary.