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COMERICA INC Director's Dealing 2013

May 2, 2013

30676_dirs_2013-05-01_18d710cf-058f-4ca5-8cde-2d2dbfe55c15.zip

Director's Dealing

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SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2013-04-23

Reporting Person: RITCHIE MICHAEL T (Executive Vice President)

Holdings (Non-Derivative)

Security Shares Ownership
Common Stock 18522 Direct

Holdings (Derivative)

Security Exercise Price Expiration Underlying Shares Ownership
Employee Stock Option (right to buy) $52.50 2014-04-16 Common Stock (2200) Direct
Employee Stock Option (right to buy) $54.99 2015-04-21 Common Stock (3200) Direct
Employee Stock Option (right to buy) $56.47 2016-02-15 Common Stock (3800) Direct
Employee Stock Option (right to buy) $58.98 2017-01-23 Common Stock (4000) Direct
Employee Stock Option (right to buy) $37.45 2018-01-22 Common Stock (4150) Direct
Employee Stock Option (right to buy) $17.32 2019-01-27 Common Stock (3750) Direct
Employee Stock Option (right to buy) $34.78 2020-01-26 Common Stock (12000) Direct
Employee Stock Option (right to buy) $39.10 2021-01-25 Common Stock (10800) Direct
Employee Stock Option (right to buy) $29.60 2022-01-24 Common Stock (8000) Direct
Employee Stock Option (right to buy) $33.79 2023-01-22 Common Stock (2000) 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 April 23, 2013. Also includes performance restricted stock units (PRSUs) which were granted to the reporting person pursuant to the Amended and Restated Comerica Incorporated 2006 Long-Term Incentive Plan. The PRSUs are settled in stock, with accrued dividend equivalents paid out annually in cash. The PRSUs vest in one installment at the end of a three-year performance period. If, during any year in such performance period, Comerica falls below the Tier 1 Capital Threshold defined by the Federal Reserve for well capitalized banks, 15% of the PRSU target award will be forfeited, with a maximum reduction of 45% of the target award. The number of PRSUs included in the total represents the portion that is not subject to such reduction as of April 23, 2013.

F2: The options vest in four equal annual installments beginning on the date indicated in this column.