8-K

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 8-K

CURRENT REPORT
Pursuant to Section 13 or 15 (d) of the
Securities Exchange Act of 1934

Date of Report (Date of Earliest Event Reported): April 15, 2004

COMERICA INCORPORATED

(Exact Name of Registrant as Specified in its Charter)

Delaware	1-10706	38-1998421
(State or other jurisdiction of	(Commission File Number)	(IRS Employer Identification
Incorporation)		Number)

Comerica Tower at Detroit Center
500 Woodward Avenue, MC 3391
Detroit, Michigan 48226

(Address of principal executive offices) (zip code)

(800) 521-1190

(Registrant’s telephone number, including area code)

TABLE OF CONTENTS

	ITEMS 9 and 12.    REGULATION FD DISCLOSURE AND DISCLOSURE OF RESULTS OF OPERATIONS AND FINANCIAL CONDITION
SIGNATURE
EXHIBIT INDEX
Press Release dated April 15, 2004
Earnings Presentation Slides

ITEMS 9 and 12.    REGULATION FD DISCLOSURE AND DISCLOSURE OF RESULTS OF OPERATIONS AND FINANCIAL CONDITION

     The registrant today released its earnings for the quarter ended March 31, 2004. A copy of the press release and the presentation slides which will be discussed in the registrant’s webcast earnings call are attached hereto as Exhibits 99.1 and 99.2, respectively.

EXHIBITS
	99.1 Press Release dated April 15, 2004
	99.2 Earnings Presentation Slides

SIGNATURE

     Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunder duly authorized.

COMERICA INCORPORATED
By:	/s/ Jon W. Bilstrom
Name:	Jon W. Bilstrom
Title:	Executive Vice President — Governance,
	Regulatory Relations and Legal Affairs,
	and Secretary

April 15, 2004

EXHIBIT INDEX

Exhibit No.	Description
99.1	Press Release dated April 15, 2004
99.2	Earnings Presentation Slides

EX-99.1

  NEWS RELEASE

EXHIBIT 99.1

COMERICA REPORTS FIRST QUARTER 2004 EARNINGS

DETROIT/April 15, 2004 — Comerica Incorporated (NYSE: CMA) today reported first quarter 2004 earnings of $162 million, or $0.92 per diluted share, compared to $176 million, or $1.00 per diluted share, for the first quarter 2003.

(dollar amounts in millions)	1st Qtr ’04			4th Qtr ’03			1st Qtr ’03
Diluted EPS	$	0.92		$	0.89		$	1.00
Net Interest Income	$	445		$	457		$	511
Net Interest Margin		3.83	%		3.83	%		4.30	%
Provision for Loan Losses	$	65		$	77		$	106
Noninterest Income	$	220		$	220		$	220
Noninterest Expenses	$	369		$	379		$	367
Net Income	$	162		$	158		$	176
Return on Equity		12.71	%		12.33	%		14.13	%

“Continued improvement in credit quality and expense control contributed to higher earnings per share in the first quarter of 2004, compared to the last quarter,” said Ralph W. Babb Jr., chairman, president and chief executive officer. “However, in the current economic environment, our commercial customers are still cautious about investing and, thus, loan demand remained soft.”

Net Interest Income

Net interest income was $445 million for the first quarter 2004, compared to $457 million for the fourth quarter 2003 and $511 million for the first quarter 2003. Average earning assets of $46.8 billion for the first quarter 2004 decreased $700 million from the fourth quarter 2003, or one percent, primarily as a result of declines in average total loans ($500 million). Average deposits for the first quarter 2004 also declined $700 million, or two percent, from the fourth quarter 2003. The decline in deposits was due to reduced levels of certificates of deposits to institutional investors and title and escrow deposits resulting from a slowdown in mortgage financing activity.

Net interest income decreased $12 million, or three percent, from the fourth quarter 2003, primarily as a result of the lower average loans in the first quarter 2004. The net interest margin was stable when compared to the fourth quarter 2003 at 3.83 percent.

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COMERICA REPORTS FIRST QUARTER 2004 EARNINGS — 2

Noninterest Income

Noninterest income was $220 million for the first quarter 2004 and the fourth and first quarters of 2003. Net securities gains were $5 million in the first quarter 2004, compared to $4 million for the fourth quarter 2003 and $13 million for the first quarter 2003.

Noninterest Expenses

Noninterest expenses were $369 million for the first quarter 2004, compared to $379 million for the fourth quarter 2003 and $367 million for the first quarter 2003. Business unit revenue-related incentives, and pension and customer service expenses all contributed to the decline from the fourth quarter 2003, partially offset by increased severance expense.

Credit Quality

(dollar amounts in millions)	1st Qtr '04			4th Qtr '03			1st Qtr '03
Net Charge-offs	$	70		$	76		$	96
Net Charge-offs/Average Total Loans		0.69	%		0.75	%		0.88	%
Provision for Loan Losses	$	65		$	77		$	106
Nonperforming Assets (NPAs)	$	522		$	538		$	641
NPAs/Total Loans, Other Real Estate & Nonaccrual Debt Securities		1.30	%		1.33	%		1.51	%
Allowance for Loan Losses	$	798		$	803		$	801
Allowance for Loan Losses/Total Loans		1.99	%		1.99	%		1.88	%
Allowance for Credit Losses on Lending-related Commitments*	$	32		$	33		$	34

* Included in “Accrued expenses and other liabilities” on the consolidated balance sheets.

During the quarter, $92 million of loans greater than $2 million were transferred to nonaccrual status, a decrease of $22 million from the fourth quarter of 2003. Nonperforming assets were $522 million at March 31, 2004, a decrease of $16 million from December 31, 2003.

Balance Sheet and Capital Management

Total assets and common shareholders’ equity were $54.5 billion and $5.1 billion, respectively, at March 31, 2004, compared to $52.6 billion and $5.1 billion, respectively, at December 31, 2003. There were approximately 173 million shares outstanding at March 31, 2004, compared to approximately 175 million shares outstanding at December 31, 2003. In the first quarter of 2004, approximately 2.4 million shares were repurchased in the open market for $133 million. Comerica’s first quarter 2004 estimated tier 1 common, tier 1 and total risk-based capital ratios were 7.98 percent, 8.65 percent and 12.60 percent, respectively.

Conference Call and Webcast

Comerica will host a conference call to review first quarter 2004 financial results at 8 a.m. ET Thursday, April 15, 2004. Interested parties may access the conference call by calling (706) 679-5261 (event ID No. 6214515). The call and supplemental financial information can be accessed via a Webcast at www.comerica.com. A replay of the conference call will be available approximately two hours following the call through Wednesday, July 14, 2004. The conference call replay can be accessed by calling (800) 642-1687 or (706) 645-9291 (event ID No. 6214515). A replay of the Webcast can also be accessed at www.comerica.com.

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COMERICA REPORTS FIRST QUARTER 2004 EARNINGS — 3

Comerica Incorporated is a financial services company headquartered in Detroit, strategically aligned into three major lines of business: the Business Bank, Small Business and Personal Financial Services, and Wealth and Institutional Management. Comerica focuses on relationships and helping businesses and people to be successful. To receive e-mail alerts of breaking Comerica news, go to www.comerica.com/newsalerts.

Forward-looking Statement

Any statements in this news release that are not historical facts are forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. Words such as “expect,” “believe,” “intend,” “estimate,” “project,” “may” and similar expressions are intended to identify forward-looking statements. These forward-looking statements are predicated on management’s beliefs and assumptions based on information known to Comerica’s management as of the date of this news release and do not purport to speak as of any other date. Forward-looking statements may include descriptions of plans and objectives of Comerica’s management for future or past operations, products or services, and forecasts of Comerica’s revenue, earnings or other measures of economic performance, including statements of profitability, business segments and subsidiaries, estimates of credit trends and global stability. Such statements reflect the view of Comerica’s management as of this date with respect to future events and are subject to risks and uncertainties. Should one or more of these risks materialize or should underlying beliefs or assumptions prove incorrect, the Company’s actual results could differ materially from those discussed. Factors that could cause or contribute to such differences are changes in the pace of an economic recovery, implementation of Comerica’s strategies and business models, management’s ability to maintain and expand customer relationships, changes in the accounting treatment of any particular item, the impact of regulatory examinations, changes in the businesses or industries in which Comerica has a concentration of loans, the anticipated performance of any new banking branches, the entry of new competitors in Comerica’s markets, changes in the level of fee income, and changes in general economic conditions and related credit and market conditions. Forward-looking statements speak only as of the date they are made. Comerica does not undertake to update forward-looking statements to reflect facts, circumstances, assumptions or events that occur after the date the forward-looking statements are made. For any forward-looking statements made in this news release or in any documents, Comerica claims the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995.

Media Contacts:	Investor Contacts:
Sharon R. McMurray	Helen L. Arsenault
(313) 222-4881 Wayne J. Mielke	(313) 222-2840 Judith M. Chavis
(313) 222-4732	(313) 222-6317

CONSOLIDATED FINANCIAL HIGHLIGHTS
Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31,			December 31,			March 31,
(in millions, except per share data)	2004			2003			2003
PER SHARE AND COMMON STOCK DATA
Diluted net income	$	0.92		$	0.89		$	1.00
Cash dividends declared		0.52			0.50			0.50
Common shareholders’ equity (at period end)		29.41			29.20			28.56
Average diluted shares (in thousands)		175,987			176,559			175,643
KEY RATIOS
Return on average common shareholders’ equity		12.71	%		12.33	%		14.13	%
Return on average assets		1.28			1.22			1.33
Average common shareholders’ equity as a percentage of average assets		10.04			9.92			9.44
Tier 1 common capital ratio *		7.98			8.04			7.47
Tier 1 risk-based capital ratio *		8.65			8.72			8.12
Total risk-based capital ratio *		12.60			12.71			11.73
Leverage ratio *		10.20			10.13			9.46
AVERAGE BALANCES
Commercial loans	$	23,087		$	23,556		$	26,313
Real estate construction loans		3,354			3,500			3,558
Commercial mortgage loans		7,964			7,727			7,254
Residential mortgage loans		874			867			809
Consumer loans		1,607			1,538			1,534
Lease financing		1,291			1,290			1,290
International loans		2,250			2,406			2,760
Total loans	$	40,427		$	40,884		$	43,518
Earning assets		46,822			47,481			48,278
Total assets		50,738			51,385			52,646
Interest-bearing deposits		26,620			27,131			27,550
Total interest-bearing liabilities		31,726			32,237			33,604
Noninterest-bearing deposits		12,985			13,198			13,288
Common shareholders’ equity		5,096			5,100			4,971
NET INTEREST INCOME
Net interest income (fully taxable equivalent basis)	$	446		$	458		$	512
Fully taxable equivalent adjustment		1			1			1
Net interest margin		3.83	%		3.83	%		4.30	%
CREDIT QUALITY
Nonaccrual loans	$	489		$	507		$	624
Other real estate		32			30			13
Nonaccrual debt securities		1			1			4
Total nonperforming assets		522			538			641
Loans past due 90 days or more and still accruing		35			32			50
Gross charge-offs		84			97			100
Recoveries		14			21			4
Net charge-offs		70			76			96
Allowance for loan losses as a percentage of total loans		1.99	%		1.99	%		1.88	%
Net loans charged off as a percentage of average total loans		0.69			0.75			0.88
Nonperforming assets as a percentage of total loans, other real estate and nonaccrual debt securities		1.30			1.33			1.51
Allowance for loan losses as a percentage of total nonperforming assets		153			149			125
ADDITIONAL DATA
Goodwill	$	247		$	247		$	247
Core deposit intangible		1			1			2
Other intangibles		1			1			1
Loan servicing rights		18			17			12
Deferred mutual fund distribution costs		11			12			17
Amortization of intangibles		—			1			—

* March 31, 2004 ratios are estimated

-4-

CONSOLIDATED BALANCE SHEETS
Comerica Incorporated and Subsidiaries

	March 31,			December 31,			March 31,
(in millions, except share data)	2004			2003			2003
ASSETS
Cash and due from banks	$	1,661		$	1,527		$	2,264
Short-term investments		5,734			4,013			4,183
Investment securities available-for-sale		4,639			4,489			4,291
Commercial loans		22,869			22,974			25,213
Real estate construction loans		3,243			3,397			3,609
Commercial mortgage loans		8,029			7,878			7,406
Residential mortgage loans		867			875			826
Consumer loans		1,601			1,568			1,532
Lease financing		1,268			1,301			1,273
International loans		2,135			2,309			2,710
Total loans		40,012			40,302			42,569
Less allowance for loan losses		(798	)		(803	)		(801	)
Net loans		39,214			39,499			41,768
Premises and equipment		378			374			369
Customers’ liability on acceptances outstanding		27			27			28
Accrued income and other assets		2,815			2,663			2,902
Total assets	$	54,468		$	52,592		$	55,805
LIABILITIES AND SHAREHOLDERS’ EQUITY
Noninterest-bearing deposits	$	17,208		$	14,104		$	17,333
Interest-bearing deposits		26,315			27,359			27,040
Total deposits		43,523			41,463			44,373
Short-term borrowings		251			262			545
Acceptances outstanding		27			27			28
Accrued expenses and other liabilities		977			929			788
Medium- and long-term debt		4,597			4,801			5,068
Total liabilities		49,375			47,482			50,802
Common stock — $5 par value:
Authorized - 325,000,000 shares Issued - 178,735,252 shares at 3/31/04, 12/31/03 and 3/31/03		894			894			894
Capital surplus		395			384			365
Accumulated other comprehensive income		92			74			192
Retained earnings		4,030			3,973			3,761
Less cost of common stock in treasury - 5,576,560 shares at 3/31/04, 3,735,163 shares at 12/31/03, and 3,576,115 shares at 3/31/03		(318	)		(215	)		(209	)
Total shareholders’ equity		5,093			5,110			5,003
Total liabilities and shareholders’ equity	$	54,468		$	52,592		$	55,805

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CONSOLIDATED STATEMENTS OF INCOME
Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31,
(in millions, except per share data)	2004		2003
INTEREST INCOME
Interest and fees on loans	$	496	$	593
Interest on investment securities		40		47
Interest on short-term investments		7		6
Total interest income		543		646
INTEREST EXPENSE
Interest on deposits		73		104
Interest on short-term borrowings		1		3
Interest on medium- and long-term debt		24		28
Total interest expense		98		135
Net interest income		445		511
Provision for loan losses		65		106
Net interest income after provision for loan losses		380		405
NONINTEREST INCOME
Service charges on deposit accounts		62		61
Fiduciary income		44		41
Commercial lending fees		14		15
Letter of credit fees		15		16
Foreign exchange income		9		10
Brokerage fees		10		8
Investment advisory revenue, net		9		7
Bank-owned life insurance		9		9
Equity in earnings of unconsolidated subsidiaries		3		2
Warrant income		1		—
Net securities gains/(losses)		5		13
Other noninterest income		39		38
Total noninterest income		220		220
NONINTEREST EXPENSES
Salaries and employee benefits		226		222
Net occupancy expense		30		32
Equipment expense		15		16
Outside processing fee expense		17		17
Software expense		11		9
Customer services		2		7
Other noninterest expenses		68		64
Total noninterest expenses		369		367
Income before income taxes		231		258
Provision for income taxes		69		82
NET INCOME	$	162	$	176
Net income applicable to common stock	$	162	$	176
Basic net income per common share	$	0.93	$	1.01
Diluted net income per common share		0.92		1.00
Cash dividends declared on common stock		90		87
Dividends per common share		0.52		0.50

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CONSOLIDATED QUARTERLY STATEMENTS OF INCOME
Comerica Incorporated and Subsidiaries

	First		Fourth		Third		Second		First		First Quarter 2004 Compared To:
	Quarter		Quarter		Quarter		Quarter		Quarter		Fourth Quarter 2003						First Quarter 2003
(in millions, except per share data)	2004		2003		2003		2003		2003		Amount			Percent			Amount			Percent
INTEREST INCOME
Interest and fees on loans	$	496	$	511	$	530	$	577	$	593	$	(15	)		(2.8	)%	$	(97	)		(16.3	)%
Interest on investment securities		40		41		37		40		47		(1	)		(5.4	)		(7	)		(14.8	)
Interest on short-term investments		7		8		12		10		6		(1	)		(2.2	)		1			18.5
Total interest income		543		560		579		627		646		(17	)		(3.0	)		(103	)		(15.9	)
INTEREST EXPENSE
Interest on deposits		73		77		86		103		104		(4	)		(5.8	)		(31	)		(29.6	)
Interest on short-term borrowings		1		1		1		2		3		—			(17.2	)		(2	)		(78.5	)
Interest on medium- and long-term debt		24		25		27		29		28		(1	)		0.1			(4	)		(12.5	)
Total interest expense		98		103		114		134		135		(5	)		(4.5	)		(37	)		(27.2	)
Net interest income		445		457		465		493		511		(12	)		(2.7	)		(66	)		(12.9	)
Provision for loan losses		65		77		83		111		106		(12	)		(15.6	)		(41	)		(38.7	)
Net interest income after provision for loan losses		380		380		382		382		405		—			(0.1	)		(25	)		(6.1	)
NONINTEREST INCOME
Service charges on deposit accounts		62		59		60		58		61		3			5.0			1			2.7
Fiduciary income		44		44		42		42		41		—			0.9			3			6.4
Commercial lending fees		14		17		16		15		15		(3	)		(20.2	)		(1	)		(12.5	)
Letter of credit fees		15		16		17		16		16		(1	)		(7.1	)		(1	)		(4.2	)
Foreign exchange income		9		6		10		9		10		3			40.3			(1	)		(12.8	)
Brokerage fees		10		10		8		8		8		—			3.1			2			26.9
Investment advisory revenue, net		9		8		8		7		7		1			6.0			2			33.5
Bank-owned life insurance		9		9		12		12		9		—			(0.8	)		—			(0.3	)
Equity in earnings of unconsolidated subsidiaries		3		1		2		1		2		2			235.1			1			81.6
Warrant income		1		3		1		—		—		(2	)		(64.7	)		1			N/M
Net securities gains		5		4		4		29		13		1			30.5			(8	)		(60.2	)
Other noninterest income		39		43		41		29		38		(4	)		(9.4	)		1			2.6
Total noninterest income		220		220		221		226		220		—			(0.1	)		—			—
NONINTEREST EXPENSES
Salaries and employee benefits		226		227		229		219		222		(1	)		(0.6	)		4			1.6
Net occupancy expense		30		32		34		30		32		(2	)		(5.2	)		(2	)		(4.5	)
Equipment expense		15		15		16		14		16		—			4.2			(1	)		(3.3	)
Outside processing fee expense		17		18		18		18		17		(1	)		(7.5	)		—			(4.2	)
Software expense		11		9		10		9		9		2			8.1			2			17.0
Customer services		2		7		6		5		7		(5	)		(67.9	)		(5	)		(67.3	)
Other noninterest expenses		68		71		64		65		64		(3	)		(4.5	)		4			6.4
Total noninterest expenses		369		379		377		360		367		(10	)		(2.9	)		2			0.5
Income before income taxes		231		221		226		248		258		10			4.8			(27	)		(10.2	)
Provision for income taxes		69		63		69		78		82		6			9.1			(13	)		(15.5	)
NET INCOME	$	162	$	158	$	157	$	170	$	176	$	4			3.0	%	$	(14	)		(7.8	)%
Net income applicable to common stock	$	162	$	158	$	157	$	170	$	176	$	4			3.0	%	$	(14	)		(7.8	)%
Basic net income per common share	$	0.93	$	0.90	$	0.90	$	0.98	$	1.01	$	0.03			3.3	%	$	(0.08	)		(7.9	)%
Diluted net income per common share		0.92		0.89		0.89		0.97		1.00		0.03			3.4			(0.08	)		(8.0	)
Cash dividends declared on common stock		90		88		88		87		87		2			2.6			3			3.2
Dividends per common share		0.52		0.50		0.50		0.50		0.50		0.02			4.0			0.02			4.0

N/M — Not meaningful

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ANALYSIS OF THE ALLOWANCE FOR LOAN LOSSES
Comerica Incorporated and Subsidiaries

	2004			2003
(in millions)	1st Qtr			4th Qtr			3rd Qtr			2nd Qtr			1st Qtr
Balance at beginning of period	$	803		$	802		$	802		$	801		$	791
Loans charged-off:
Commercial		65			75			71			87			72
Real estate construction:
Real estate construction business line		—			1			—			—			—
Other		—			—			—			—			1
Total real estate construction		—			1			—			—			1
Commercial mortgage:
Commercial real estate business line		—			—			—			4			—
Other		6			6			4			3			5
Total commercial mortgage		6			6			4			7			5
Consumer		2			2			2			2			2
Lease financing		8			—			—			4			—
International		3			13			17			17			20
Total loans charged-off		84			97			94			117			100
Recoveries on loans previously charged-off:
Commercial		10			16			5			6			2
Real estate construction		—			—			—			—			—
Commercial mortgage		—			—			1			—			—
Consumer		—			—			1			—			1
Lease financing		1			—			—			—			—
International		3			5			4			1			1
Total recoveries		14			21			11			7			4
Net loans charged-off		70			76			83			110			96
Provision for loan losses		65			77			83			111			106
Balance at end of period	$	798		$	803		$	802		$	802		$	801
Allowance for loan losses as a percentage of total loans		1.99	%		1.99	%		1.97	%		1.89	%		1.88	%
Net loans charged-off as a percentage of average total loans		0.69			0.75			0.79			1.02			0.88
Allowance for credit losses on lending-related commitments*	$	32		$	33		$	29		$	33		$	34

* Included in “Accrued expenses and other liabilities” on the consolidated balance sheets.

-8-

NONPERFORMING ASSETS
Comerica Incorporated and Subsidiaries

	2004			2003
(in millions)	1st Qtr			4th Qtr			3rd Qtr			2nd Qtr			1st Qtr
SUMMARY OF NONPERFORMING ASSETS AND PAST DUE LOANS
Nonaccrual loans:
Commercial	$	286		$	300		$	388		$	346		$	400
Real estate construction:
Real estate construction business line		19			21			28			37			38
Other		5			3			4			3			1
Total real estate construction		24			24			32			40			39
Commercial mortgage:
Commercial real estate business line		3			3			3			3			8
Other		90			84			65			52			49
Total commercial mortgage		93			87			68			55			57
Residential mortgage		3			1			—			—			—
Consumer		2			3			3			2			2
Lease financing		13			24			25			26			35
International		68			68			82			90			91
Total nonaccrual loans		489			507			598			559			624
Reduced-rate loans		—			—			—			—			—
Total nonperforming loans		489			507			598			559			624
Other real estate		32			30			25			18			13
Nonaccrual debt securities		1			1			4			4			4
Total nonperforming assets	$	522		$	538		$	627		$	581		$	641
Nonperforming loans as a percentage of total loans		1.22	%		1.26	%		1.47	%		1.32	%		1.47	%
Nonperforming assets as a percentage of total loans, other real estate and nonaccrual debt securities		1.30			1.33			1.54			1.37			1.51
Allowance for loan losses as a percentage of total nonperforming assets		153			149			128			138			125
Loans past due 90 days or more and still accruing	$	35		$	32		$	56		$	42		$	50
ANALYSIS OF NONACCRUAL LOANS
Nonaccrual loans at beginning of period	$	507		$	598		$	559		$	624		$	565
Loans transferred to nonaccrual (1)		92			114			211			148			187
Nonaccrual business loan gross charge-offs (2)		(81	)		(94	)		(92	)		(115	)		(98	)
Loans transferred to accrual status (1)		—			—			—			(6	)		(9	)
Nonaccrual business loans sold (3)		(14	)		(48	)		(37	)		(56	)		(3	)
Payments/Other (4)		(15	)		(63	)		(43	)		(36	)		(18	)
Nonaccrual loans at end of period	$	489		$	507		$	598		$	559		$	624
(1) Based on an analysis of nonaccrual loans with book balances greater than $2 million.
(2) Analysis of gross loan charge-offs:
Nonaccrual business loans	$	81		$	94		$	92		$	115		$	98
Performing watch list loans sold		1			1			—			—			—
Consumer loans		2			2			2			2			2
Total gross loan charge-offs	$	84		$	97		$	94		$	117		$	100
(3) Analysis of loans sold:
Nonaccrual business loans	$	14		$	48		$	37		$	56		$	3
Performing watch list loans sold		18			15			—			—			—
Total loans sold	$	32		$	63		$	37		$	56		$	3
(4) Net change related to nonaccrual loans with balances less than $2 million, other than business loan gross
charge-offs and nonaccrual loans sold, are included in Payments/Other.

-9-

ANALYSIS OF NET INTEREST INCOME (FTE)
Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31, 2004								December 31, 2003								March 31, 2003
	Average					Average			Average					Average			Average					Average
(dollar amounts in millions)	Balance			Interest		Rate			Balance			Interest		Rate			Balance			Interest		Rate
Commercial loans	$	23,087		$	233		4.06	%	$	23,556		$	242		4.08	%	$	26,313		$	273		4.20	%
Real estate construction loans		3,354			42		5.01			3,500			44		5.00			3,558			45		5.14
Commercial mortgage loans		7,964			100		5.03			7,727			100		5.11			7,254			101		5.65
Residential mortgage loans		874			13		6.07			867			13		6.16			809			14		6.84
Consumer loans		1,607			20		4.95			1,538			17		4.48			1,534			22		5.90
Lease financing		1,291			14		4.40			1,290			15		4.58			1,290			17		5.12
International loans		2,250			23		4.11			2,406			26		4.36			2,760			30		4.41
Business loan swap income		—			52		—			—			54		—			—			92		—
Total loans		40,427			497		4.94			40,884			511		4.97			43,518			594		5.53
Investment securities available-for-sale (1)		4,551			40		3.48			4,792			42		3.47			3,972			47		4.74
Short-term investments		1,844			7		1.66			1,805			8		1.72			788			6		3.31
Total earning assets		46,822			544		4.67			47,481			561		4.69			48,278			647		5.43
Cash and due from banks		1,664								1,703								1,799
Allowance for loan losses		(831	)							(832	)							(826	)
Accrued income and other assets		3,083								3,033								3,395
Total assets	$	50,738							$	51,385							$	52,646
Money market and NOW deposits	$	17,908			42		0.95		$	17,991			44		0.98		$	16,452			55		1.35
Savings deposits		1,607			2		0.39			1,592			2		0.42			1,549			2		0.61
Certificates of deposit		6,515			26		1.58			6,991			28		1.58			8,862			41		1.87
Foreign office time deposits		590			3		2.41			557			4		2.62			687			6		3.40
Total interest-bearing deposits		26,620			73		1.10			27,131			78		1.13			27,550			104		1.53
Short-term borrowings		311			1		0.89			334			1		0.98			976			3		1.33
Medium- and long-term debt		4,795			24		2.06			4,772			24		2.04			5,078			28		2.23
Total interest-bearing sources		31,726			98		1.25			32,237			103		1.27			33,604			135		1.63
Noninterest-bearing deposits		12,985								13,198								13,288
Accrued expenses and other liabilities		931								850								783
Common shareholders’ equity		5,096								5,100								4,971
Total liabilities and shareholders’ equity	$	50,738							$	51,385							$	52,646
Net interest income/rate spread (FTE)				$	446		3.42					$	458		3.42					$	512		3.80
FTE adjustment				$	1							$	1							$	1
Impact of net noninterest-bearing sources of funds							0.41								0.41								0.50
Net interest margin (as a percentage of average earning assets) (FTE)							3.83	%							3.83	%							4.30	%

(1) The average rate for investment securities available-for-sale was computed using average historical cost.

-10-

CONSOLIDATED STATISTICAL DATA
Comerica Incorporated and Subsidiaries

	March 31,			December 31,			September 30,			June 30,			March 31,
(in millions, except per share data)	2004			2003			2003			2003			2003
Commercial loans:
Floor plan	$	2,797		$	2,731		$	2,053		$	2,752		$	2,715
Other		20,072			20,243			21,333			22,321			22,498
Total commercial loans		22,869			22,974			23,386			25,073			25,213
Real estate construction loans:
Real estate construction business line		2,628			2,754			2,866			2,959			3,016
Other		615			643			630			619			593
Total real estate construction loans		3,243			3,397			3,496			3,578			3,609
Commercial mortgage loans:
Commercial real estate business line		1,718			1,655			1,574			1,687			1,682
Other		6,311			6,223			6,057			5,920			5,724
Total commercial mortgage loans		8,029			7,878			7,631			7,607			7,406
Residential mortgage loans		867			875			844			828			826
Consumer loans:
Home equity		1,193			1,176			1,110			1,127			1,121
Other consumer		408			392			401			369			411
Total consumer loans		1,601			1,568			1,511			1,496			1,532
Lease financing		1,268			1,301			1,289			1,275			1,273
International loans		2,135			2,309			2,478			2,607			2,710
Total loans	$	40,012		$	40,302		$	40,635		$	42,464		$	42,569
Goodwill	$	247		$	247		$	247		$	247		$	247
Core deposit intangible		1			1			2			2			2
Other intangible assets		1			1			1			1			1
Loan servicing rights		18			17			16			14			12
Deferred mutual fund distribution costs		11			12			14			15			17
Amortization of intangibles (quarterly)		—			1			—			—			—
Tier 1 common capital ratio*		7.98	%		8.04	%		7.92	%		7.61	%		7.47	%
Tier 1 risk-based capital ratio*		8.65			8.72			8.58			8.26			8.12
Total risk-based capital ratio *		12.60			12.71			12.64			12.30			11.73
Leverage ratio*		10.20			10.13			9.54			9.38			9.46
Book value per share	$	29.41		$	29.20		$	29.05		$	29.02		$	28.56
Market value per share for the quarter:
High	$	59.23		$	56.34		$	49.75		$	53.58		$	46.74
Low		52.30			46.38			45.28			37.79			37.10
Close		54.32			56.06			46.60			46.50			37.88
Quarterly ratios:
Return on average common shareholders’ equity		12.71	%		12.33	%		12.55	%		13.51	%		14.13	%
Return on average assets		1.28			1.22			1.16			1.27			1.33
Efficiency ratio		55.84			56.34			55.28			52.02			51.10
Number of banking offices		362			360			358			357			352
Number of employees — full time equivalent		11,237			11,282			11,302			11,479			11,477

* March 31, 2004 ratios are estimated

-11-

PARENT COMPANY ONLY BALANCE SHEETS
Comerica Incorporated

	March 31,			December 31,			March 31,
(in millions, except share data)	2004			2003			2003
ASSETS
Cash and due from banks	$	—		$	—		$	17
Short-term investments with subsidiary bank		227			296			60
Investment in subsidiaries, principally banks		5,643			5,599			5,502
Premises and equipment		3			3			3
Other assets		309			262			284
Total assets	$	6,182		$	6,160		$	5,866
LIABILITIES AND SHAREHOLDERS’ EQUITY
Commercial paper	$	—		$	—		$	100
Long-term debt		839			826			176
Subordinated debt issued to and advances from subsidiaries		—			—			353
Other liabilities		250			224			234
Total liabilities		1,089			1,050			863
Common stock — $5 par value:
Authorized — 325,000,000 shares Issued — 178,735,252 shares at 3/31/04, 12/31/03 and 3/31/03		894			894			894
Capital surplus		395			384			365
Accumulated other comprehensive income		92			74			192
Retained earnings		4,030			3,973			3,761
Less cost of common stock in treasury — 5,576,560 shares at 3/31/04, 3,735,163 shares at 12/31/03 and 3,576,115 shares at 3/31/03		(318	)		(215	)		(209	)
Total shareholders’ equity		5,093			5,110			5,003
Total liabilities and shareholders’ equity	$	6,182		$	6,160		$	5,866

CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY
Comerica Incorporated and Subsidiaries

						Accumulated
						Other									Total
	Common		Capital			Comprehensive			Retained			Treasury			Shareholders’
(in millions, except share data)	Stock		Surplus			Income			Earnings			Stock			Equity
BALANCE AT JANUARY 1, 2003	$	894	$	363		$	237		$	3,684		$	(231	)	$	4,947
Net income		—		—			—			176			—			176
Other comprehensive loss, net of tax		—		—			(45	)		—			—			(45	)
Total comprehensive income		—		—			—			—			—			131
Cash dividends declared on common stock ($0.50 per share)		—		—			—			(87	)		—			(87	)
Net issuance of common stock under employee stock plans		—		(5	)		—			(12	)		22			5
Recognition of stock-based compensation expense		—		7			—			—			—			7
BALANCE AT MARCH 31, 2003	$	894	$	365		$	192		$	3,761		$	(209	)	$	5,003
BALANCE AT JANUARY 1, 2004	$	894	$	384		$	74		$	3,973		$	(215	)	$	5,110
Net income		—		—			—			162			—			162
Other comprehensive income, net of tax		—		—			18			—			—			18
Total comprehensive income		—		—			—			—			—			180
Cash dividends declared on common stock ($0.52 per share)		—		—			—			(90	)		—			(90	)
Purchase of 2,376,593 shares of common stock		—		—			—			—			(133	)		(133	)
Net issuance of common stock under employee stock plans		—		5			—			(15	)		30			20
Recognition of stock-based compensation expense		—		6			—			—			—			6
BALANCE AT MARCH 31, 2004	$	894	$	395		$	92		$	4,030		$	(318	)	$	5,093

-12-

EX-99.2

Exhibit 99.2

First Quarter 2004 Financial Review Comerica Incorporated April 15, 2004

Safe Harbor Statement This presentation and the oral statements relating to this presentation (the "Presentation") that are not historical facts are forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. Words such as "expect", "believe", "intend", "estimate", "project", "may" and similar expressions are intended to identify forward-looking statements. These forward-looking statements are predicated on management's beliefs and assumptions based on information known to Comerica's management as of the date of this Presentation and do not purport to speak as of any other date. Forward-looking statements may include descriptions of plans and objectives of Comerica's management for future or past operations, products or services, and forecasts of the Company's revenues, earnings or other measures of economic performance, including statements of profitability, business segments and subsidiaries, estimates of credit trends and global stability. Such statements reflect the view of Comerica's management, as of the date of this Presentation, with respect to future events and are subject to risks and uncertainties. Should one or more of these risks materialize or should underlying beliefs or assumptions prove incorrect, the Company's actual results could differ materially from those discussed in this Presentation. Factors that could cause or contribute to such differences are changes in the pace of an economic recovery, implementation of Comerica's strategies and business models, management's ability to maintain and expand customer relationships, changes in the accounting treatment of any particular item, the impact of regulatory examinations, changes in the businesses or industries in which Comerica has a concentration of loans, the anticipated performance of any new banking branches, the entry of new competitors in Comerica's markets, changes in the level of fee income, and changes in general economic conditions and related credit and market conditions. Forward-looking statements speak only as of the date they are made in this Presentation. Comerica does not undertake to update forward-looking statements to reflect facts, circumstances, assumptions or events that occur after the date the forward-looking statements are made. For any forward-looking statements made in this presentation or in any documents, Comerica claims the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995.

Agenda This presentation provides an overview of the first quarter 2004 financial performance for Comerica Incorporated. All information contained herein has been made public. Please refer to our press release and financial statements for additional detail. Highlights Income Statement Loan Growth Credit Quality Deposit Growth Capital Management Outlook Questions & Answers Appendix

Highlights Y - Y% 1Q04 4Q03 Q - Q% CHANGE 1Q03 CHANGE ---- ---- ------- ---- ------ Net Income $162 $158 3% $176 -8% Diluted EPS $0.92 $0.89 3% $1.00 -8% Return on Equity 12.71% 12.33% 14.13% Net Interest Income $445 $457 -3% $511 -13% Net Interest Margin 3.83% 3.83% 4.30% Provision for Loan Losses $65 $77 -16% $106 -39% Non-interest Income $220 $220 0% $220 0% Non-interest Expense $369 $379 -3% $367 1% $ in millions

Net Interest Income & Margin Net Interest Income down $12 MM (3%) from 4Q03 to $445 MM Net Interest Margin of 3.83% is unchanged from 4Q03 primarily due to: short-term liquidity held at 4Q03 levels margin contribution from swaps sustained at 4Q03 levels 1Q03 2Q03 3Q03 4Q03 1Q04 0.043 0.0398 0.037 0.0383 0.0383

Non-Interest Income Q-Q % CHANGE Y-Y % CHANGE ------- ------- 1Q04 4Q03 1Q03 Service Charges on Deposit Accounts $62 $59 5% $61 3% Fiduciary Income 44 44 1% 41 6% Commercial Lending Fees 14 17 -20% 15 -13% Letter of Credit Fees 15 16 -7% 16 -4% Foreign Exchange Income 9 6 40% 10 -13% Brokerage Fees 10 10 3% 8 27% Investment Advisory Rev, Net 9 8 6% 7 34% Bank-owned Life Insurance 9 9 -1% 9 0% Equity in Earnings of Unconsolidated Subsidiaries 3 1 N/M 2 N/M Warrant Income 1 3 N/M 0 N/M Net Securities Gains / (Losses) 5 4 31% 13 -60% Other Non-interest Income 39 43 -9% 38 3% $220 $220 0% $220 0% Non-Interest Income N/M = Not Meaningful % change based on full dollar amounts

Non-Interest Expenses Q-Q % CHANGE Y-Y % CHANGE ------- ------- 1Q04 4Q03 1Q03 Salaries & Employee Benefits $226 $227 -1% $222 2% 30 32 -5% 32 -5% NET OCCUPANCY EXPENSE Equipment Expense 15 15 4% 16 -3% Outside Processing Fees 17 18 -8% 17 -4% Software Expense 11 9 8% 9 17% Customer Services 2 7 -68% 7 -67% Other Non-Interest Expenses 68 71 -5% 64 6% $369 $379 -3% $367 1% Non-Interest Expenses % change based on full dollar amounts

Geographic Loan Growth 1Q04 4Q03 Q-Q % CHANGE 1Q03 Y-Y % CHANGE ---- ---- ------- ---- ------- Midwest, Int'l & Other $23.1 $23.9 -3% $25.2 -9% Western Region 11.6 11.5 1% 12.5 -8% Texas 4.5 4.4 1% 4.6 -2% Florida 1.2 1.1 10% 1.2 7% $40.4 $40.9 -1% $43.5 -7% TOTAL Avg loans in $billions; % change based on full dollar amounts. Geography based on location of loan office. Western Region includes: CA, AZ, NV, CO, WA

Line of Business Loan Growth % CHG % CHG 1Q04 4Q03 1Q03 ---- ---- ---- Middle Market $13.6 $13.9 -2% $14.0 -2% Commercial Real Estate 5.6 5.7 -2% 6.3 -11% Global Corporate Banking 4.9 5.2 -6% 6.6 -26% National Dealer Services 4.1 3.7 11% 3.8 7% Specialty Businesses* 3.4 3.8 -10% 4.3 -21% $31.6 $32.3 -2% $35.0 -10% SUBTOTAL - BUSINESS BANK 3.4 3.3 1% 3.3 1% Small Business 2.4 2.4 1% 2.3 5% Personal Financial Services $5.8 $5.7 1% $5.6 5% SUBTOTAL - SMALL BUSINESS & PERSONAL FINANCIAL SERVICES 3.0 2.9 2% 2.9 3% Private Banking $3.0 $2.9 2% $2.9 3% SUBTOTAL - WEALTH & INSTITUTIONAL MANAGEMENT TOTAL $40.4 $40.9 -1% $43.5 -7% Average loans outstanding in $billions; % change based on full dollar value. *Specialty Businesses includes: Entertainment, Energy, FSG, Leasing & TLS

First Quarter Credit Quality Non-Accrual Loans Line of Business: Middle Market 52% Global Corporate 21% Small Business 11% Industry: Automotive 24% Services 13% Retail Trade 9% Midwest Western Division Texas 0.6519 0.31 0.0382 Midwest, Int'l & Other 65% Western Region 31% Texas 4% Geography based on location of loan office. Western Region includes: CA, AZ, NV, CO

Three Months Ended Dollar amounts in millions. Net change for balances <$2 MM, other than business loan charge-offs and loans sold, included in Payments / Other. Credit Quality Non-Accrual Loans 03/31/04 12/31/03 09/30/03 06/30/03 03/31/03 -------- -------- -------- -------- -------- BALANCE AT BEGINNING OF PERIOD $507 $598 $559 $624 $565 Transfers to nonaccrual 92 114 211 148 187 Nonaccrual business loan gross charge-offs (81) (94) (92) (115) (98) Transfers to accrual status -- -- -- (6) (9) Nonaccrual business loans sold (14) (48) (37) (56) (3) Payments / Other (15) (63) (43) (36) (18) BALANCE AT END OF PERIOD $489 $507 $598 $559 $624

Line of Business: Middle Market 70% Leasing 12% Global Corporate 11% Industry: Technology-related 18% Wholesale Trade 16% Manufacturing 15% Michigan & Nat'l Businesses Western Division Texas 40743 26607 2784 Texas 4% Western Region 38% Midwest, Int'l & Other 58% Geography based on location of loan office. Western Region includes: CA, AZ, NV,CO,WA First Quarter Credit Quality Net Charge Offs

1Q 2003 2Q 2003 3Q 2003 4Q 2003 1Q 2004 East 0.0188 0.0189 0.0197 0.0199 0.0199 Credit Quality - Reserves $801 $802 $802 $803 Allowance ($millions) 1.99% $798 1.99%

Line of Business Deposit Growth % CHG % CHG 1Q04 4Q03 1Q03 ---- ---- ---- Middle Market $4.4 $4.6 -2% $4.1 10% Commercial Real Estate 1.0 1.1 -9% 1.0 -7% Global Corporate Banking 1.9 1.8 4% 1.5 23% National Dealer Services 0.2 0.1 7% 0.1 11% Specialty Businesses1 10.0 10.0 0% 11.1 -10% $17.5 $17.6 -1% $17.8 -3% SUBTOTAL - BUSINESS BANK 4.9 5.1 -3% 4.6 8% Small Business 13.1 13.2 -1% 13.1 0% Personal Financial Services $18.0 $18.3 -1% $17.7 2% SUBTOTAL - SMALL BUSINESS & PERSONAL FINANCIAL SERVICES 2.4 2.4 0% 1.9 29% Private Banking $2.4 $2.4 0% $1.9 29% SUBTOTAL - WEALTH & INSTITUTIONAL MANAGEMENT Finance/Other2 1.7 2.0 -15% 3.4 -49% TOTAL $39.6 $40.3 -2% $40.8 -3% Average deposits in $billions; % change based on full dollar value. 1Specialty Businesses includes: Entertainment, Energy, FSG, Leasing & TLS 2Finance/Other includes Institutional CD's: 1Q04 - $1.1B; 4Q03 - $1.5B; 1Q03 - $2.7B

Capital Management Estimated capital ratios: Tier 1 common 7.98% Tier 1 8.65% Total risk-based 12.60% Common shareholder's equity: $5.1 billion Approximately 2.4 million shares ($133 million) repurchased in the first quarter 2004. Remaining authorization: 12.4 million shares

Full-year 2004 Trends Average loans slightly lower, with low-single digit end of period loan growth Low-single digit non-interest income growth, excluding securities gains Average net interest margin relatively unchanged from first quarter 2004 Flat to $20 million reduction in non-interest expenses Average net charge-offs of approximately 60 basis points

Questions & Answers Ralph Babb, Chairman, President & CEO Beth Acton, EVP & Chief Financial Officer Dale Greene, EVP & Chief Credit Officer & Helen Arsenault, Director of Investor Relations

Appendix

1Q 2004 Average Loans Midwest, Int'l & ---------- Other Western TEXAS Florida TOTAL ----- ------- ----- ------- ----- Middle Market $8.4 $4.0 $1.1 $0.2 $13.6 Commercial Real Estate 2.7 1.7 1.0 0.3 5.6 Global Corporate Banking 4.3 0.4 0.2 0.0 4.9 National Dealer Services 0.7 2.6 0.2 0.5 4.1 Specialty Businesses* 1.4 1.3 0.7 0.0 3.4 $17.5 $10.0 $3.2 $1.0 $31.6 SUBTOTAL - BUSINESS BANK 1.7 0.9 0.8 0.0 3.4 Small Business 2.3 0.0 0.1 0.0 2.4 Personal Financial Services $4.0 $0.9 $0.9 $0.0 $5.8 SUBTOTAL - SMALL BUSINESS & PERSONAL FINANCIAL SERVICES 1.6 0.7 0.4 0.2 3.0 Private Banking $1.6 $0.7 $0.4 $0.2 $3.0 SUBTOTAL - WEALTH & INSTITUTIONAL MANAGEMENT TOTAL $23.1 $11.6 $4.5 $1.2 $40.4 $ in billions *Specialty Businesses includes: Entertainment, Energy, FSG, Leasing & TLS

1Q 2004 Average Deposits Midwest, Int'l & ---------- Other Western TEXAS Florida TOTAL ------ ------- ----- ------- ----- Middle Market $1.0 $3.2 $0.2 $0.0 $4.4 Commercial Real Estate 0.6 0.2 0.1 0.1 1.0 Global Corporate Banking 1.8 0.1 0.1 0.0 1.9 National Dealer Services 0.1 0.1 0.0 0.0 0.2 Specialty Businesses1 0.8 8.6 0.5 0.0 10.0 $4.3 $12.2 $0.9 $0.1 $17.5 SUBTOTAL - BUSINESS BANK 3.3 0.7 0.9 0.0 4.9 Small Business 10.8 0.6 1.6 0.1 13.1 Personal Financial Services $14.1 $1.3 $2.5 $0.1 $18.0 SUBTOTAL - SMALL BUSINESS & PERSONAL FINANCIAL SERVICES 0.7 1.4 0.3 0.0 2.4 Private Banking $0.7 $1.4 $0.3 $0.0 $2.4 SUBTOTAL - WEALTH & INSTITUTIONAL MANAGEMENT Finance/Other2 1.7 0.0 0.0 0.0 1.7 TOTAL $20.8 $14.9 $3.7 $0.2 $39.6 $ in billions 1Specialty Businesses includes: Entertainment, Energy, FSG, Leasing & TLS 2 Finance/Other includes $1.1 billion in Institutional CD's