COMERICA INC - Director's Dealing 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: Duprey David E (EVP and General Auditor)

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2011-01-25	Common Stock	A	9000	—	Acquired	65631	Direct

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-01-25	Employee Stock Option (right to buy)	$39.10	A	18500	Acquired	2021-01-25	Common Stock (18500)	Direct

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$57.97	2016-03-31	Common Stock (10000)	10000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (18800)	18800	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 (17000)	17000	Direct
Phantom Stock Units	$	2011-02-05	Common Stock (8712)	8712	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (18500)	18500	Direct

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

F2: Includes shares acquired through employee stock plans and shares purchased with reinvested dividends 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.