COMERICA INC — Director's Dealing 2009

Apr 27, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-04-23

Reporting Person: BERAN JOHN R (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2009-04-23	Common Stock	S	100	$20.47	Disposed	98466	Direct
2009-04-23	Common Stock	S	300	$20.48	Disposed	98166	Direct
2009-04-23	Common Stock	S	100	$20.49	Disposed	98066	Direct
2009-04-23	Common Stock	S	521	$20.51	Disposed	97545	Direct
2009-04-23	Common Stock	S	879	$20.52	Disposed	96666	Direct
2009-04-23	Common Stock	S	200	$20.53	Disposed	96466	Direct
2009-04-23	Common Stock	S	400	$20.54	Disposed	96066	Direct
2009-04-23	Common Stock	S	600	$20.55	Disposed	95466	Direct
2009-04-23	Common Stock	S	600	$20.56	Disposed	94866	Direct
2009-04-23	Common Stock	S	500	$20.57	Disposed	94366	Direct
2009-04-23	Common Stock	S	200	$20.58	Disposed	94166	Direct
2009-04-23	Common Stock	S	100	$20.60	Disposed	94066	Direct
2009-04-23	Common Stock	S	200	$20.61	Disposed	93866	Direct
2009-04-23	Common Stock	S	100	$20.63	Disposed	93766	Direct
2009-04-23	Common Stock	S	919	$20.64	Disposed	92847	Direct
2009-04-23	Common Stock	S	800	$20.65	Disposed	92047	Direct
2009-04-23	Common Stock	S	300	$20.66	Disposed	91747	Direct
2009-04-23	Common Stock	S	400	$20.67	Disposed	91347	Direct
2009-04-23	Common Stock	S	1100	$20.68	Disposed	90247	Direct
2009-04-23	Common Stock	S	200	$20.69	Disposed	90047	Direct
2009-04-23	Common Stock	S	300	$20.70	Disposed	89747	Direct
2009-04-23	Common Stock	S	600	$20.72	Disposed	89147	Direct
2009-04-23	Common Stock	S	100	$20.73	Disposed	89047	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$41.50	2010-03-17	Common Stock (17400)	17400	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (15800)	15800	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (26000)	26000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (35000)	35000	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
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (32000)	32000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (24500)	24500	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 23, 2009.

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