COMERICA INC — Director's Dealing 2011

Feb 8, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-02-05

Reporting Person: Duprey David E (EVP and General Auditor)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-02-05	Common Stock	M	8712	—	Acquired	74432	Direct
2011-02-05	Common Stock	D	8712	$38.60	Disposed	65720	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-02-05	Phantom Stock Units	$	M	8712	Disposed	2011-02-05	Common Stock (8712)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$57.97	2016-03-31	Common Stock (10000)	10000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (18800)	18800	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (20000)	20000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (17000)	17000	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 (18500)	18500	Direct

Footnotes

F1: Each share of phantom stock was the economic equivalent of one share of Comerica Incorporated common stock. The shares of phantom stock were settled for cash.

F2: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of February 4, 2011.

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

F4: The phantom stock units represent a portion of the reporting person's base salary.

F5: Phantom stock units will be settled in cash on the earlier to occur of February 5, 2011 or the reporting person's death.