COMERICA INC — Director's Dealing 2006

Feb 16, 2006

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2006-02-15

Reporting Person: Beck Mary Constance (EVP - Retail Bank)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2006-02-15	Common Stock	A	9000	—	Acquired	26316	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2006-02-15	Employee Stock Option (right to buy)	$56.47	A	34000	Acquired	2016-02-15	Common Stock (34000)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (45000)	45000	Direct
Employee Stock Option (right to buy)	$60.70	2014-11-03	Common Stock (30000)	30000	Direct

Footnotes

F1: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of February 15, 2006.

F2: The options vest in four equal annual installments beginning on the date indicated in this column.