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: ELENBAAS MARVIN J (SVP & Chief Accounting Officer)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-04-21	Common Stock	A	760	—	Acquired	20790	Direct

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	5600	Acquired	2015-04-21	Common Stock (5600)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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)	$41.50	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)	$63.20	2012-04-17	Common Stock (6400)	6400	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (1900)	1900	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (4100)	4100	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.