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COMERICA INC Director's Dealing 2006

Dec 15, 2006

30676_dirs_2006-12-15_23b68d27-c418-4c1e-a8a2-79cb997e4771.zip

Director's Dealing

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SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2006-12-13

Reporting Person: CUMMINGS PETER D (Director)

Non-Derivative Transactions

Date Security Code Shares Price A/D Holdings After Ownership
2006-12-13 Common Stock G 38505 Disposed 3816 Indirect

Holdings (Non-Derivative)

Security Shares Ownership
Common Stock 11168 Direct

Holdings (Derivative)

Security Exercise Price Expiration Underlying Shares Ownership
Director Stock Option (right to buy) $40.09 2007-05-16 Common Stock (1500) 1500 Direct
Director Stock Option (right to buy) $65.13 2008-05-15 Common Stock (1500) 1500 Direct
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: Includes stock units held pursuant to deferred director plans, restricted stock units, and shares purchased with reinvested dividends as of December 13, 2006.

F2: Reporting person's spouse has gifted these shares to a foundation.

F3: The reporting person disclaims beneficial ownership of these shares, and this report shall not be deemed an admission that the reporting person is the beneficial owner of these shares for purposes of Section 16 or for any other purpose.

F4: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F5: 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.