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: ACTON ELIZABETH S (EVP and CFO)

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2011-01-07	Phantom Stock Units	$	A	410	Acquired	2011-02-05	Common Stock (410)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	82093	Direct

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (right to buy)	$62.02	2012-04-13	Common Stock (30000)	30000	Direct
Employee Stock Option (right to buy)	$52.50	2014-04-16	Common Stock (45000)	45000	Direct
Employee Stock Option (right to buy)	$54.99	2015-04-21	Common Stock (45000)	45000	Direct
Employee Stock Option (right to buy)	$56.47	2016-02-15	Common Stock (32000)	32000	Direct
Employee Stock Option (right to buy)	$58.98	2017-01-23	Common Stock (32000)	32000	Direct
Employee Stock Option (right to buy)	$37.45	2018-01-22	Common Stock (32000)	32000	Direct
Employee Stock Option (right to buy)	$17.32	2019-01-27	Common Stock (17400)	17400	Direct
Employee Stock Option (right to buy)	$39.16	2020-07-27	Common Stock (18500)	18500	Direct

Footnotes

F1: 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 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.