COMERICA INC — Director's Dealing 2009

Feb 24, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-02-20

Reporting Person: BERAN JOHN R (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2009-02-20	Common Stock	A	9970	$13.5785	Acquired	100324	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (20000)	20000	Direct
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: 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.

F2: Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and stock units held pursuant to a deferred compensation plan as of February 20, 2009.

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