COMERICA INC — Director's Dealing 2004

Mar 19, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

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

Reporting Person: BUTTIGIEG JOSEPH J III (Director, Vice Chairman / Director)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	79635	Direct
Common Stock	838	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$18.59	2005-04-18	Common Stock (16500)	16500	Direct
Employee Stock Option (right to buy)	$25.42	2006-04-14	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$40.25	2007-04-20	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (25000)	25000	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (40000)	40000	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: This report is being disclosed voluntarily in accordance with new internal company policies. 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 register the shares jointly with his spouse.