COMERICA INC — Director's Dealing 2006

May 1, 2006

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2006-04-28

Reporting Person: BUTTIGIEG JOSEPH J III (Director, Vice Chairman / Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2006-04-28	Common Stock	J	3120	$56.87	Disposed	106646	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$40.25	2007-04-20	Common Stock (18000)	18000	Direct
Employee Stock Option (right to buy)	$71.58	2008-03-20	Common Stock (25000)	25000	Direct
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (40000)	40000	Direct
Employee Stock Option (right to buy)	$41.50	2010-03-17	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (70000)	70000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (68000)	68000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (50000)	50000	Direct

Footnotes

F1: Reflects the payment of tax liability on vested shares of restricted stock through the surrender of previously owned shares to the issuer.

F2: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of April 28, 2006.

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