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: GREENE DALE E (EVP - Business Bank)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-02-05	Common Stock	M	10922	—	Acquired	148319	Direct
2011-02-05	Common Stock	D	10922	$38.60	Disposed	137397	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-02-05	Phantom Stock Units	$	M	10922	Disposed	2011-02-05	Common Stock (10922)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	155	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (14500)	14500	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (23600)	23600	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (23400)	23400	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 (33000)	33000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (26700)	26700	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (22500)	22500	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, shares purchased with reinvested dividends and stock units held pursuant to a deferred compensation plan as of February 4, 2011.

F3: Includes shares purchased with reinvested dividends.

F4: The options vest in four equal annual installments beginning on the date indicated in this column.

F5: The phantom stock units represent a portion of the reporting person's base salary.

F6: Phantom stock units will be settled in cash on the earlier to occur of February 5, 2011 or the reporting person's death.