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: Ogden Thomas D (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-01-25	Common Stock	A	8000	—	Acquired	49868	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	17000	Acquired	2021-01-25	Common Stock (17000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	5	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$51.43	2011-05-02	Common Stock (6600)	6600	Direct
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (12000)	12000	Direct
Employee Stock Option (right to buy)	$40.32	2013-04-17	Common Stock (11900)	11900	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (8500)	8500	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (12000)	12000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (10600)	10600	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (12000)	12000	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 (20700)	20700	Direct
Phantom Stock Units	$	2011-02-05	Common Stock (7342)	7342	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (13000)	13000	Direct

Footnotes

F1: Shares of restricted stock awarded under issuer's Long-Term Incentive Plan.

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 January 25, 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: Each phantom stock unit is the economic equivalent of one share of Comerica Incorporated common stock.

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