Sec Form 4 Filing - Beck Mary Constance @ COMERICA INC /NEW/ - 2011-01-31

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

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, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person Beck Mary Constance 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) EVP - Retail Bank (Last) (First) (Middle) COMERICA INCORPORATED, 1717 MAIN STREET, MC 6403 3. Date of Earliest Transaction (MM/DD/YY) 01/31/2011 (Street) DALLAS, TX75201 4. If Amendment, Date Original Filed (MM/DD/YY) 6. Individual or Joint/Group Filing (Check Applicable Line) __ X __ Form filed by One Reporting Person _____ Form filed by More than One Reporting Person (City) (State) (Zip)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned 1.Title of Security (Instr. 3) 2. Transaction Date (MM/DD/YY) 2A. Deemed Execution Date, if any (MM/DD/YY) 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) Code V Amount (A) or (D) Price Common Stock 01/31/2011 F 19,708 D $ 38.2 71,962 ( 1 ) D

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 (MM/DD/YY) 3A. Deemed Execution Date, if any (MM/DD/YY) 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 (MM/DD/YY) 7. Title and Amount of Underlying Securities (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 of Derivative Security: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4) Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares Employee Stock Option (right to buy) $ 60.7 11/03/2005( 2 ) 11/03/2014 Common Stock 30,000 30,000 D Employee Stock Option (right to buy) $ 54.99 01/25/2006( 2 ) 04/21/2015 Common Stock 45,000 45,000 D Employee Stock Option (right to buy) $ 56.47 01/24/2007( 2 ) 02/15/2016 Common Stock 34,000 34,000 D Employee Stock Option (right to buy) $ 58.98 01/23/2008( 2 ) 01/23/2017 Common Stock 34,000 34,000 D Employee Stock Option (right to buy) $ 37.45 01/22/2009( 2 ) 01/22/2018 Common Stock 34,000 34,000 D Employee Stock Option (right to buy) $ 17.32 01/27/2010( 2 ) 01/27/2019 Common Stock 26,500 26,500 D Phantom Stock Units ( 3 ) ( 4 ) 02/05/2011( 5 ) 02/05/2011( 5 ) Common Stock 13,008 13,008 D Employee Stock Option (right to buy) $ 39.16 07/27/2011( 2 ) 07/27/2020 Common Stock 21,000 21,000 D

Reporting Owners Reporting Owner Name / Address Relationships Director 10% Owner Officer Other Beck Mary Constance COMERICA INCORPORATED 1717 MAIN STREET, MC 6403 DALLAS, TX75201 EVP - Retail Bank Signatures /s/ Nicole V. Gersch, on behalf of Mary Constance Beck through Power of Attorney 02/01/2011 Signature of Reporting Person Date

Explanation of Responses:

( 1 )Includes shares acquired through employee stock plans and shares purchased with reinvested dividends as of January 31, 2011. ( 2 )The options vest in four equal annual installments beginning on the date indicated in this column. ( 3 )The phantom stock units represent a portion of the reporting person's base salary. ( 4 )Each phantom stock unit is the economic equivalent of one share of Comerica Incorporated common stock. ( 5 )Phantom stock units will be settled in cash on the earlier to occur of February 5, 2011 or the reporting person's death.

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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