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: ACTON ELIZABETH S (Exec. V. Pres., CFO & Treas.)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-04-21	Common Stock	A	6000	—	Acquired	38929	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	45000	Acquired	2015-04-21	Common Stock (45000)	Direct

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
Employee Stock Option (Right to Buy)	$40.32	2013-04-17	Common Stock (20000)	20000	Direct
Employee Stock Option (Right to Buy)	$52.50	2014-04-16	Common Stock (45000)	45000	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.