COMERICA INC — Director's Dealing 2009

Apr 10, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-04-08

Reporting Person: BAUDER LILLIAN (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2009-04-08	Common Stock	A	190	$16.42	Acquired	28498	Direct
2009-04-08	Common Stock	A	371	$16.42	Acquired	28869	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Director Stock Option (right to buy)	$62.75	2009-05-21	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$64.50	2012-05-21	Common Stock (2500)	2500	Direct
Restricted Stock Units	$0	1988-08-08	Common Stock (319)	319	Direct

Footnotes

F1: The shares were acquired by reporting person in connection with a distribution from one of issuer's director deferral plans.

F2: The shares that were acquired by reporting person in connection with this transaction have been included in Table I of previous filings, and accordingly, this transaction does not vary the amount of securities beneficially owned by reporting person (other than fractional share differences).

F3: 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.

F4: Includes, among other things, stock units held pursuant to deferred director plans, resticted stock units, and shares purchased with reinvested dividends as of April 8, 2009.

F5: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F6: The restricted stock units vest one year after the date of grant. Vested shares are settled one year after cessation of service on the board.