COMERICA INC — Director's Dealing 2004

Jan 28, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-01-27

Reporting Person: ACTON ELIZABETH S (EVP/Chief Financial Officer)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-01-27	Common Stock	M	10000	$40.32	Acquired	36486	Direct
2004-01-27	Common Stock	S	10000	$58.04	Disposed	26486	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-01-27	Employee Stock Option (right to buy)	$40.32	M	10000	Disposed	2013-04-17	Common Stock (10000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	64	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$62.02	2012-04-13	Common Stock (30000)	30000	Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of December 1, 2003.

F2: As of December 1, 2003.

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