COMERICA INC — Director's Dealing 2009

Nov 19, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-11-17

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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2009-11-17	Common Stock	A	6994	$28.76	Acquired	79625	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
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (34000)	34000	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (34000)	34000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (26500)	26500	Direct

Footnotes

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

F2: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of November 17, 2009.

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