Regulatory Capital and Reserve Requirements

12 Months Ended

Dec. 31, 2012

Regulatory Capital Requirements [Abstract]

Regulatory Capital and Reserve Requirements

REGULATORY CAPITAL AND RESERVE REQUIREMENTS

Reserves required to be maintained and/or deposited with the FRB are classified in interest-bearing deposits with banks. These reserve balances vary, depending on the level of customer deposits in the Corporation’s banking subsidiaries. The average required reserve balances were $360 million and $335 million for the years ended December 31, 2012 and 2011, respectively.

Banking regulations limit the transfer of assets in the form of dividends, loans or advances from the bank subsidiaries to the parent company. Under the most restrictive of these regulations, the aggregate amount of dividends which can be paid to the parent company, with prior approval from bank regulatory agencies, approximated $277 million at January 1, 2013, plus 2013 net profits. Substantially all the assets of the Corporation’s banking subsidiaries are restricted from transfer to the parent company of the Corporation in the form of loans or advances.

The Corporation’s subsidiary banks declared dividends of $497 million, $292 million and $28 million in 2012, 2011 and 2010, respectively.

The Corporation and its U.S. banking subsidiaries are subject to various regulatory capital requirements administered by federal and state banking agencies. Quantitative measures established by regulation to ensure capital adequacy require the maintenance of minimum amounts and ratios of Tier 1 and total capital (as defined in the regulations) to average and risk-weighted assets. Failure to meet minimum capital requirements can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a direct material effect on the Corporation’s financial statements. At December 31, 2012 and 2011, the Corporation and its U.S. banking subsidiaries exceeded the ratios required for an institution to be considered “well capitalized” (total risk-based capital, Tier 1 risk-based capital and leverage ratios greater than 10 percent, 6 percent and 5 percent, respectively). There have been no conditions or events since December 31, 2012 that management believes have changed the capital adequacy classification of the Corporation or its U.S. banking subsidiaries.

The following is a summary of the capital position of the Corporation and Comerica Bank, its principal banking subsidiary.

(dollar amounts in millions)	Comerica Incorporated (Consolidated)			Comerica Bank
December 31, 2012
Tier 1 capital (minimum-$2.6 billion (Consolidated))	$	6,705		$	6,700
Total capital (minimum-$5.3 billion (Consolidated))	8,695			8,570
Risk-weighted assets	66,188			65,996
Average assets (fourth quarter)	63,720			63,525
Tier 1 capital to risk-weighted assets (minimum-4.0%)	10.13		%	10.15		%
Total capital to risk-weighted assets (minimum-8.0%)	13.14			12.99
Tier 1 capital to average assets (minimum-3.0%)	10.52			10.55
December 31, 2011
Tier 1 capital (minimum-$2.5 billion (Consolidated))	$	6,582		$	6,596
Total capital (minimum-$5.1 billion (Consolidated))	9,015			8,849
Risk-weighted assets	63,244			63,029
Average assets (fourth quarter)	60,301			60,065
Tier 1 capital to risk-weighted assets (minimum-4.0%)	10.41		%	10.47		%
Total capital to risk-weighted assets (minimum-8.0%)	14.25			14.04
Tier 1 capital to average assets (minimum-3.0%)	10.92			10.98