COMERICA INC — Director's Dealing 2005

Jan 31, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-01-27

Reporting Person: MOORADIAN DENNIS J (Exec. VP, Wealth & Inst. Mgt.)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-01-27	Common Stock	P	500	$56.93	Acquired	44194	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	36	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.9	2013-11-04	Common Stock (60000)	60000	Direct
Employee Stock Option (right to buy)	$52.5	2014-04-16	Common Stock (45000)	45000	Direct

Footnotes

F1: This number includes shares acquired through employee stock plans as of January 30, 2005.

F2: As of January 30, 2005.

F3: The option vests in four equal annual installments beginning on the date indicated in this column.