COMERICA INC — Director's Dealing 2005

May 4, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-04-21

Reporting Person: LAKE JAMES E (SVP/Dir. of Human Resources)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2005-04-21	Employee Stock Option (right to buy)	$54.99	A	5000	Acquired	2015-04-21	Common Stock (5000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	14218	Direct
Common Stock	19	Indirect
Common Stock	13	Indirect
Common Stock	17	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (3325)	3325	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (3650)	3650	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (838)	838	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (4600)	4600	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (3375)	3375	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (5000)	5000	Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of May 3, 2005.

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