COMERICA INC — Director's Dealing 2011

Feb 1, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-01-31

Reporting Person: Beck Mary Constance (EVP - Retail Bank)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-01-31	Common Stock	F	19708	$38.20	Disposed	71962	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$60.70	2014-11-03	Common Stock (30000)	30000	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 (34000)	34000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (34000)	34000	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (34000)	34000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (26500)	26500	Direct
Phantom Stock Units	$	2011-02-05	Common Stock (13008)	13008	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (21000)	21000	Direct

Footnotes

F1: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of January 31, 2011.

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

F3: The phantom stock units represent a portion of the reporting person's base salary.

F4: Each phantom stock unit is the economic equivalent of one share of Comerica Incorporated common stock.

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