COMERICA INC — Director's Dealing 2005

Oct 5, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-10-03

Reporting Person: WALLINGTON PATRICIA M (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-10-03	Common Stock	A	65	$59.47	Acquired	4351	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Director Stock Option (right to buy)	$62.75	2009-05-21	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$44.13	2010-05-19	Common Stock (2000)	2000	Direct
Director Stock Option (right to buy)	$57.15	2011-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$64.50	2012-05-21	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$43.63	2013-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$53.87	2014-05-18	Common Stock (2500)	2500	Direct
Restricted Stock Units	$0	1988-08-08	Common Stock (319)	319	Direct

Footnotes

F1: Stock units acquired under a deferral plan. The units are being reported in Table I because they are distributed in the form of common stock, on a one-for-one basis.

F2: Includes stock units held pursuant to deferred director plans, restricted stock units, and shares purchased with reinvested dividends as of October 4, 2005.

F3: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F4: The restricted stock units vest one year after the date of grant. Vested shares are settled one year after cessation of service on the board.