COMERICA INC — Director's Dealing 2004

Jan 21, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2004-01-16

Reporting Person: FULTON J MICHAEL (Pres/CEO-Comerica Bank-W. Div.)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-01-16	Common Stock	J	13	$56.76	Acquired	36765	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	8134	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$18.59	2005-04-18	Common Stock (13500)	13500	Direct
Employee Stock Option (right to buy)	$25.42	2006-04-14	Common Stock (12000)	12000	Direct
Employee Stock Option (right to buy)	$40.25	2007-04-20	Common Stock (15000)	15000	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 (25000)	25000	Direct
Employee Stock Option (right to buy)	$41.5	2010-03-17	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (16200)	16200	Direct
Employee Stock Option (right to buy)	$63.2	2012-04-17	Common Stock (25800)	25800	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (24700)	24700	Direct

Footnotes

F1: Matching contribution made by the issuer pursuant to the Employee Stock Purchase Plan.

F2: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of January 2, 2003.

F3: As of December 1, 2003.

F4: The options vest in four equal annual installments beginning on the date indicated in this column.