COMERICA INC — Director's Dealing 2011

Jan 27, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-01-25

Reporting Person: ANDERSON LARS C (Vice Chairman)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-01-25	Common Stock	A	35000	—	Acquired	50000	Direct
2011-01-25	Common Stock	A	11500	—	Acquired	61500	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-01-25	Employee Stock Option (right to buy)	$39.10	A	24000	Acquired	2021-01-25	Common Stock (24000)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$42.24	2020-12-31	Common Stock (30000)	30000	Direct

Footnotes

F1: Restricted stock units granted pursuant to the Comerica Incorporated 2006 Long-Term Incentive Plan. Each restricted stock unit represents an unfunded, unsecured right to receive one share of Comerica common stock. The restricted stock units vest in three equal installments on the fourth, sixth and eighth anniversaries of the grant date and are settled in stock on March 4, 2021.

F2: Includes shares acquired through employee stock plans as of January 25, 2011.

F3: Shares of restricted stock awarded under issuer's Long-Term Incentive Plan.

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