SEC FORM 4

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

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Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

1. Name and Address of Reporting Person^*

GUMMER CHARLES L

(Last)

(First)

(Middle)

COMERICA BANK

1601 ELM ST.

(Street)

DALLAS

75201

(City)

(State)

(Zip)

2. Issuer Name and Ticker or Trading Symbol
COMERICA INC /NEW/ [ CMA ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director	10% Owner
X	Officer (give title below)	Other (specify below)
	Pres&CEO-Comerica Bank-Tex Div

3. Date of Earliest Transaction (Month/Day/Year)
02/17/2004

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	Amount	(A) or (D)	Price		6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
Common Stock	02/17/2004		M		4,250	A	$18	66,189⁽¹⁾	D
Common Stock	02/18/2004		S		1,100	D	$57.22	65,089⁽¹⁾	D
Common Stock	02/18/2004		S		3,150	D	$57.21	61,939⁽¹⁾	D
Common Stock								4,781⁽²⁾	I	by 401(k)
Common Stock								1,500	I	by Spouse

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	8. Price of Derivative Security (Instr. 5)		10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
Employee Stock Option (right to buy)	$18	02/17/2004		M			4,250	01/20/1995⁽³⁾	04/19/2004	Common Stock	4,250	$0	0	D
Employee Stock Option (right to buy)	$18.59							01/19/1996⁽³⁾	04/18/2005	Common Stock	16,500		16,500	D
Employee Stock Option (right to buy)	$25.42							01/17/1997⁽³⁾	04/14/2006	Common Stock	18,000		18,000	D
Employee Stock Option (right to buy)	$40.25							01/20/1998⁽³⁾	04/20/2007	Common Stock	18,000		18,000	D
Employee Stock Option (right to buy)	$71.58							01/15/1999⁽³⁾	03/20/2008	Common Stock	25,000		25,000	D
Employee Stock Option (right to buy)	$66.81							01/14/2000⁽³⁾	03/19/2009	Common Stock	25,000		25,000	D
Employee Stock Option (right to buy)	$41.5							01/19/2001⁽³⁾	03/17/2010	Common Stock	18,000		18,000	D
Employee Stock Option (right to buy)	$51.43							01/22/2002⁽³⁾	05/02/2011	Common Stock	15,800		15,800	D
Employee Stock Option (right to buy)	$63.2							01/21/2003⁽³⁾	04/17/2012	Common Stock	24,800		24,800	D
Employee Stock Option (right to buy)	$40.32							01/27/2004⁽³⁾	04/17/2013	Common Stock	24,500		24,500	D

Explanation of Responses:

1. This number includes shares purchased under the CMA dividend reinvestment plan and shares acquired through employee stock plans as of January 30, 2004.

2. As of January 30, 2004.

3. The option vests in four equal annual installments beginning on the date indicated in this column.

	/s/ Nicole V. Gersch, on behalf of Charles L. Gummer	02/19/2004
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
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