COMERICA INC — Director's Dealing 2009

Apr 17, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-04-16

Reporting Person: BABB RALPH W JR (Director, Chairman, President & CEO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2009-04-16	Common Stock	F	4441	$20.32	Disposed	391220	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (75000)	75000	Direct
Employee Stock Option (right to buy)	$54.95	2011-09-30	Common Stock (50000)	50000	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (125000)	125000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (120000)	70000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (150000)	150000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (175000)	175000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (100000)	100000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (100000)	100000	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (100000)	100000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (83600)	83600	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 16, 2009.

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