COMERICA INC — Director's Dealing 2007

Jan 30, 2007

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2007-01-23

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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2007-01-23	Common Stock	A	9000	—	Acquired	36520	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2007-01-23	Employee Stock Option (right to buy)	$58.98	A	34000	Acquired	2017-01-23	Common Stock (34000)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$60.70	2014-11-03	Common Stock (30000)	30000	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

Footnotes

F1: Shares of restricted stock awarded under Issuer's Long-Term Incentive Plan.

F2: This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of January 29, 2007.

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