COMERICA INC — Director's Dealing 2007

Apr 20, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-04-19

Reporting Person: FULTON J MICHAEL (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-19	Common Stock	S	200	$62.95	Disposed	67047	Direct
2007-04-19	Common Stock	S	1100	$62.94	Disposed	65947	Direct
2007-04-19	Common Stock	S	300	$62.93	Disposed	65647	Direct
2007-04-19	Common Stock	S	100	$62.92	Disposed	65547	Direct
2007-04-19	Common Stock	S	1500	$62.91	Disposed	64047	Direct
2007-04-19	Common Stock	S	1800	$62.90	Disposed	62247	Direct
2007-04-19	Common Stock	S	600	$62.89	Disposed	61647	Direct
2007-04-19	Common Stock	S	600	$62.87	Disposed	61047	Direct
2007-04-19	Common Stock	S	500	$62.86	Disposed	60547	Direct
2007-04-19	Common Stock	S	200	$62.85	Disposed	60347	Direct
2007-04-19	Common Stock	S	100	$62.84	Disposed	60247	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
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 (16200)	16200	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (25800)	25800	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (24700)	24700	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (40000)	40000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (40000)	40000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (32000)	32000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (32000)	32000	Direct

Footnotes

F1: Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and stock units held pursuant to a deferred compensation plan as of April 19, 2007.

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