COMERICA INC — Director's Dealing 2011

Jan 11, 2011

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2011-01-07

Reporting Person: FARMER CURTIS C (EVP/Wealth & Inst. Mgmt.)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-01-07	Phantom Stock Units	$	A	400	Acquired	2011-02-05	Common Stock (400)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	29647	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$21.95	2018-01-14	Common Stock (18750)	18750	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (13725)	13725	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 as of January 7, 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.