COMERICA INC — Director's Dealing 2011

Mar 3, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-03-01

Reporting Person: ACTON ELIZABETH S (EVP and CFO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-03-01	Common Stock	S	100	$38.63	Disposed	91141	Direct
2011-03-01	Common Stock	S	535	$38.65	Disposed	90606	Direct
2011-03-01	Common Stock	S	300	$38.66	Disposed	90306	Direct
2011-03-01	Common Stock	S	912	$38.67	Disposed	89394	Direct
2011-03-01	Common Stock	S	253	$38.69	Disposed	89141	Direct
2011-03-01	Common Stock	S	200	$38.72	Disposed	88941	Direct
2011-03-01	Common Stock	S	300	$38.77	Disposed	88641	Direct
2011-03-01	Common Stock	S	100	$38.81	Disposed	88541	Direct
2011-03-01	Common Stock	S	100	$38.85	Disposed	88441	Direct
2011-03-01	Common Stock	S	300	$38.86	Disposed	88141	Direct
2011-03-01	Common Stock	S	200	$38.90	Disposed	87941	Direct
2011-03-01	Common Stock	S	200	$38.91	Disposed	87741	Direct
2011-03-01	Common Stock	S	613	$38.99	Disposed	87128	Direct
2011-03-01	Common Stock	S	100	$39.00	Disposed	87028	Direct
2011-03-01	Common Stock	S	200	$39.01	Disposed	86828	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$62.02	2012-04-13	Common Stock (30000)	30000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (45000)	45000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (45000)	45000	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 (11600)	11600	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (18500)	18500	Direct
Employee Stock Option (right to buy)	$39.10	2021-01-25	Common Stock (23500)	23500	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 March 1, 2011.

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