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: Burkhart Megan D (EVP - Chief HR Officer)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-01-25	Common stock	A	5000	—	Acquired	7800	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	11000	Acquired	2021-01-25	Common Stock (11000)	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$63.20	2012-04-17	Common Stock (1000)	1000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (363)	363	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (2750)	2750	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (2200)	2200	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (3200)	3200	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (2800)	2800	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (2100)	2100	Direct
Employee Stock Option (right to buy)	$34.78	2020-01-26	Common Stock (15000)	15000	Direct

Footnotes

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

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

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