COMERICA INC — Director's Dealing 2007

Feb 27, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-02-23

Reporting Person: MOORADIAN DENNIS J (EVP/Wealth & Inst. Mgt.)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-02-23	Common Stock	A	5514	—	Acquired	81716	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.90	2013-11-04	Common Stock (60000)	60000	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 (34000)	34000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (34000)	34000	Direct

Footnotes

F1: Stock units acquired under a deferral plan. The units are being reported in Table I because they are distributed in the form of common stock, on a one-for-one basis.

F2: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of February 27, 2007.

F3: The options vest in four equal annual installments beginning on the date indicated in this column.