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: BABB RALPH W JR (Director, Chairman, President & CEO)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	92205	Direct
Common Stock	2404	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Common Stock	$21	2005-07-01	Common Stock (22500)	22500	Direct
Common Stock	$25.42	2006-04-14	Common Stock (18000)	18000	Direct
Common Stock	$40.25	2007-04-20	Common Stock (21000)	21000	Direct
Common Stock	$71.58	2008-03-20	Common Stock (25000)	25000	Direct
Common Stock	$66.81	2009-03-19	Common Stock (40000)	40000	Direct
Common Stock	$41.5	2010-03-17	Common Stock (75000)	75000	Direct
Common Stock	$51.43	2011-05-02	Common Stock (75000)	75000	Direct
Common Stock	$54.95	2011-09-30	Common Stock (50000)	50000	Direct
Common Stock	$63.2	2012-04-17	Common Stock (125000)	125000	Direct
Common Stock	$40.32	2013-04-17	Common Stock (120000)	120000	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.