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COMERICA INC Director's Dealing 2006

May 1, 2006

30676_dirs_2006-05-01_734f3e24-0fab-4ba4-b2d6-ce2754a623f4.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: 2006-04-28

Reporting Person: GUMMER CHARLES L (Pres/CEO-Comerica Bank-Tex Div)

Non-Derivative Transactions

Date Security Code Shares Price A/D Holdings After Ownership
2006-04-28 Common Stock J 926 $56.87 Disposed 78993 Direct

Holdings (Non-Derivative)

Security Shares Ownership
Common Stock 1500 Indirect

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 (25000) 25000 Direct
Employee Stock Option (right to buy) $41.50 2010-03-17 Common Stock (18000) 18000 Direct
Employee Stock Option (right to buy) $51.43 2011-05-02 Common Stock (15800) 15800 Direct
Employee Stock Option (right to buy) $63.20 2012-04-17 Common Stock (24800) 24800 Direct
Employee Stock Option (right to buy) $40.32 2013-04-17 Common Stock (24500) 24500 Direct
Employee Stock Option (right to buy) $52.50 2014-04-16 Common Stock (25000) 25000 Direct
Employee Stock Option (right to buy) $54.99 2015-04-21 Common Stock (25000) 25000 Direct
Employee Stock Option (right to buy) $56.47 2016-02-15 Common Stock (20500) 20500 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 reporting person no longer has a reportable beneficial interest in 1,400 shares owned by his son and included in the reporting person's prior ownership reports.

F4: The options vest in four equal annual installments beginning on the date indicated in this column.