COMERICA INC — Director's Dealing 2006

May 3, 2006

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2006-05-03

Reporting Person: VITITOE WILLIAM P (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2006-05-03	Common Stock	M	1500	$29.08	Acquired	10143	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2006-05-03	Director Stock Option (right to buy)	$29.08	M	1500	Disposed	2006-05-17	Common Stock (1500)	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 reported in Table I and shares purchased with reinvested dividends as of May 3, 2006.

F2: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F3: 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.