COMERICA INC — Director's Dealing 2009

Jan 29, 2009

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2009-01-27

Reporting Person: ELENBAAS MARVIN J (SVP & Chief Accounting Officer)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2009-01-27	Employee Stock Option (right to buy)	$17.32	A	8200	Acquired	2019-01-27	Common Stock (8200)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	24606	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$66.81	2009-03-19	Common Stock (5950)	5950	Direct
Employee Stock Option (right to buy)	$41.50	2010-03-17	Common Stock (5950)	5950	Direct
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (5324)	5324	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (6400)	6400	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (1900)	1900	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (4100)	4100	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (5600)	5600	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (4800)	4800	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (4500)	4500	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (5000)	5000	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 January 27, 2009.

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