Ownership Submission
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 OF SECURITIES

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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(Print or Type Responses)
1. Name and Address of Reporting Person *
BILSTROM JON W
   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 & Secretary
(Last)
(First)
(Middle)
COMERICA INCORPORATED, 1717 MAIN STREET, MC 6404		 3. Date of Earliest Transaction (Month/Day/Year)
01/07/2011
(Street)

DALLAS, TX 75201		 4. If Amendment, Date 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
(City)
(State)
(Zip)
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)
Code V Amount (A) or (D) Price
Common Stock               78,157 (1) D  
Common Stock               1,500 I by Jon W. Bilstrom Agency
Common Stock               2,000 I by Kathy Keeler Bilstrom Trust Agency

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
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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 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) $ 44.91             01/02/2004(2) 01/02/2013 Common Stock 20,000   20,000 D  
Employee Stock Option (right to buy) $ 52.5             01/26/2005(2) 04/16/2014 Common Stock 25,000   25,000 D  
Employee Stock Option (right to buy) $ 54.99             01/25/2006(2) 04/21/2015 Common Stock 25,000   25,000 D  
Employee Stock Option (right to buy) $ 56.47             01/24/2007(2) 02/15/2016 Common Stock 25,000   25,000 D  
Employee Stock Option (right to buy) $ 58.98             01/23/2008(2) 01/23/2017 Common Stock 25,000   25,000 D  
Employee Stock Option (right to buy) $ 37.45             01/22/2009(2) 01/22/2018 Common Stock 25,000   25,000 D  
Employee Stock Option (right to buy) $ 17.32             01/27/2010(2) 01/27/2019 Common Stock 20,300   20,300 D  
Phantom Stock Units (3) (4) 01/07/2011   A   341   02/05/2011(5) 02/05/2011(5) Common Stock 341 $ 0 9,230 D  
Employee Stock Option (right to buy) $ 39.16             07/27/2011(2) 07/27/2020 Common Stock 18,500   18,500 D  

Reporting Owners

Reporting Owner Name / Address Relationships
 Director  10% Owner  Officer  Other
BILSTROM JON W
COMERICA INCORPORATED
1717 MAIN STREET, MC 6404
DALLAS, TX 75201		       EVP & Secretary  

Signatures

 /s/ Jennifer S. Perry, on behalf of Jon W. Bilstrom through Power of Attorney   01/11/2011
**Signature of Reporting Person Date

Explanation of Responses:

* 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).
(1) 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.
(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.

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