COMERICA INC — Director's Dealing 2011

Feb 16, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-02-14

Reporting Person: ACTON ELIZABETH S (EVP and CFO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-02-14	Common Stock	S	5800	$39.79	Disposed	93093	Direct
2011-02-15	Common Stock	F	1852	$39.74	Disposed	91241	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 February 14, 2011.

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