EX-99.1 2 k58854ex99-1.txt LETTER TO THE FEDERAL RESERVE BANK 1 EXHIBIT 99.1 Comerica Tower at Detroit Center Corporate Legal Department 500 Woodward Avenue, 33rd Floor Detroit, Michigan 48226 (313) 222-7464 (313) 222-9480 - Facsimile Julius L. Loeser Senior Vice President and Deputy General Counsel VIA FACSIMILE (312)-913-2479 & VIA AIRBORNE EXPRESS November 28, 2000 Jack Wixted, Senior Vice President Federal Reserve Bank of Chicago 230 South LaSalle Street Chicago, IL 60604-1413 Re: Declaration of Election to be Financial Holding Company Dear Mr. Wixted: We are filing on behalf of Comerica Incorporated, currently a bank holding company, pursuant to Section 4(l)(i) of the Bank Holding Company Act (12 U.S.C.ss.1843 (l)(i)) and Section 225.82 of the Board's Regulation Y, this written declaration of its election to become a financial holding company. 1. Statement Election Comerica Incorporated elects to be a financial holding company. 2. Company and Each Depository Institution Subsidiary The name of the company is Comerica Incorporated. The address of its head office is 500 Woodward Avenue, Detroit, Michigan 48226. The name and address of each depository institution subsidiary is: a.) Comerica Bank 500 Woodward Avenue Detroit, Michigan 48226 2 Jack Wixted, Senior Vice President Federal Reserve Bank of Chicago November 28, 2000 Page 2 b.) Comerica Bank-California 333 W. Santa Clara Street San Jose, California 95113 c.) Comerica Bank-Texas Thanksgiving Tower 1601 Elm Street Dallas, Texas 72201 d.) Comerica Bank, N.A. 3450 West Central Avenue Suite 230 Toledo, Ohio 43606 e.) Comerica Bank & Trust, N.A. 101 North Main Street Ann Arbor, Michigan 48104 3. Capitalization I hereby certify that all depository institutions controlled by the company are well capitalized as of this date. 4. Capital Ratios The capital ratios for all relevant capital measures as of the close of the previous quarter for each depository institution controlled by the company on this date are set forth in the attachment to this letter. 5. Management The undersigned hereby certifies that all depository institutions controlled by the company are "well-managed", as of the date of this letter. 3 Jack Wixted, Senior Vice President Federal Reserve Bank of Chicago November 28, 2000 Page 3 Thank you for your consideration of this declaration. If you have any questions about what we propose, we would be pleased to answer them. Best wishes, /s/ Julius L. Loeser cc: Mitchell Doepke 4 Jack Wixted, Senior Vice President Federal Reserve Bank of Chicago November 28, 2000 Page 4 bcc: Ralph Babb Marvin Elenbaas Michael Fidler John Gonzalez George Madison Ronald Marks Michael Michalak Eugene Miller Jay Oberg Thomas Ogden Mark Yonkman 5 Summary of Risk-Based Capital and Leverage Ratios September 30, 2000
Tier 1 Tier 2 Risk-adj. Adj. Total Leverage Tier I Total Capital Capital Assets Assets (i) Ratio (2) Ratio Ratio ------- ------- --------- ---------- --------- ------ ----- Comerica Consolidated 3,501,522 2,018,126 49,795,692 40,191,509 8.71% 7.03% 11.08% Comerica Bank 2,826,598 1,702,353 40,186,867 32,325,393 8.74% 7.03% 11.27% Comerica Bank - Texas 401,711 148,045 3,815,643 3,758,472 10.69% 10.53% 14.41% Comerica Bank - California 457,543 207,538 6,198,916 5,134,600 8.91% 7.38% 10.73% Comerica Bank, N,A. 8,845 -- 2,346 10,241 86.37% 377.02% 377.02% Comerica Bank & Trust, N.A. 1,124 -- 508 1,495 75.18% 221.26% 221.26%
(1) Adjusted total assets are defined as the quarterly average total assets reported on the FRY-9C or the call report, less goodwill and other intangibles acquired after February, 1992. (2) Tier 1 capital divided by adjusted total assets.