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: ACTON ELIZABETH S (Exec. V. Pres. and CFO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-04-19	Common Stock	S	1900	$62.39	Disposed	71262	Direct
2007-04-19	Common Stock	S	500	$62.38	Disposed	70762	Direct
2007-04-19	Common Stock	S	1000	$62.37	Disposed	69762	Direct
2007-04-19	Common Stock	S	200	$62.34	Disposed	69562	Direct
2007-04-19	Common Stock	S	1700	$62.28	Disposed	67862	Direct
2007-04-19	Common Stock	S	300	$62.27	Disposed	67562	Direct
2007-04-19	Common Stock	S	100	$62.25	Disposed	67462	Direct
2007-04-19	Common Stock	S	300	$62.23	Disposed	67162	Direct
2007-04-19	Common Stock	S	600	$62.21	Disposed	66562	Direct
2007-04-19	Common Stock	S	500	$62.20	Disposed	66062	Direct
2007-04-19	Common Stock	S	500	$62.19	Disposed	65562	Direct
2007-04-19	Common Stock	S	1000	$62.18	Disposed	64562	Direct
2007-04-19	Common Stock	S	300	$62.17	Disposed	64262	Direct
2007-04-19	Common Stock	S	900	$62.16	Disposed	63362	Direct
2007-04-19	Common Stock	S	1700	$62.15	Disposed	61662	Direct
2007-04-19	Common Stock	S	1200	$62.14	Disposed	60462	Direct
2007-04-19	Common Stock	S	2700	$62.13	Disposed	57762	Direct
2007-04-19	Common Stock	S	4100	$62.12	Disposed	53662	Direct
2007-04-19	Common Stock	S	421	$62.11	Disposed	53241	Direct
2007-04-19	Common Stock	S	1800	$62.10	Disposed	51441	Direct
2007-04-19	Common Stock	S	900	$62.09	Disposed	50541	Direct
2007-04-19	Common Stock	S	1379	$62.08	Disposed	49162	Direct
2007-04-19	Common Stock	S	600	$62.07	Disposed	48562	Direct
2007-04-19	Common Stock	S	600	$62.06	Disposed	47962	Direct
2007-04-19	Common Stock	S	700	$62.05	Disposed	47262	Direct
2007-04-19	Common Stock	S	100	$62.04	Disposed	47162	Direct
2007-04-19	Common Stock	S	400	$62.03	Disposed	46762	Direct
2007-04-19	Common Stock	S	500	$62.02	Disposed	46262	Direct
2007-04-19	Common Stock	S	200	$62.01	Disposed	46062	Direct
2007-04-19	Common Stock	S	900	$62.00	Disposed	45162	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (Right to Buy)	$62.02	2012-04-13	Common Stock (30000)	30000	Direct
Employee Stock Option (Right to Buy)	$52.50	2014-04-16	Common Stock (45000)	45000	Direct
Employee Stock Option (Right to Buy)	$54.99	2015-04-21	Common Stock (45000)	45000	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.