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: ELENBAAS MARVIN J (SVP & Chief Accounting Officer)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-03-12	Common Stock	A	184	—	Acquired	17609	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1797	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (Right to Buy)	$18.59	2005-04-18	Common Stock (3600)	3600	Direct
Employee Stock Option (Right to Buy)	$25.42	2006-04-14	Common Stock (3450)	3450	Direct
Employee Stock Option (Right to Buy)	$40.25	2007-04-20	Common Stock (3600)	3600	Direct
Employee Stock Option (Right to Buy)	$71.58	2008-03-20	Common Stock (5500)	5500	Direct
Employee Stock Option (Right to Buy)	$66.81	2009-03-19	Common Stock (5950)	5950	Direct
Employee Stock Option (Right to Buy)	$41.5	2010-03-17	Common Stock (5950)	5950	Direct
Employee Stock Option (Right to Buy)	$51.43	2011-05-02	Common Stock (5324)	5324	Direct
Employee Stock Option (Right to Buy)	$63.2	2012-04-17	Common Stock (6400)	6400	Direct
Employee Stock Option (Right to Buy)	$40.32	2013-04-17	Common Stock (1900)	1900	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.