COMERICA INC — Director's Dealing 2007

Jul 25, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-07-24

Reporting Person: BAUDER LILLIAN (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-07-24	Common Stock	A	1101	—	Acquired	25595	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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)	$64.50	2012-05-21	Common Stock (2500)	2500	Direct
Restricted Stock Units	$0	1988-08-08	Common Stock (319)	319	Direct

Footnotes

F1: Restricted stock units granted pursuant to the Comerica Incorporated Amended and Restated Incentive Plan for Non-Employee Directors. Each restricted stock unit represents an unfunded, unsecured right to receive one share of Comerica common stock. The restricted stock units vest one year after the date of grant and are settled in stock one year after cessation of service on the board.

F2: Includes stock units held pursuant to deferred director plans, resticted stock units, and shares purchased with reinvested dividends as of July 24, 2007.

F3: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F4: 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.