COMERICA INC — Director's Dealing 2004

Mar 16, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-03-12

Reporting Person: BILSTROM JON W (EVP/ Secretary)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-03-12	Common Stock	A	177	—	Acquired	8527	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1500	Indirect
Common Stock	2000	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$44.91	2013-01-02	Common Stock (20000)	20000	Direct

Footnotes

F1: This number includes shares acquired through employee stock plans as of
March 12, 2004.

F2: The options vest in four equal annual installments beginning on the date indicated in this column.