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 21, 2010

COMERICA INCORPORATED

(Exact name of registrant as specified in its charter)

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

Comerica Bank Tower

1717 Main Street, MC 6404

Dallas, Texas  75201

(Address of principal executive offices)   (zip code)

(214) 462-6831

(Registrant’s telephone number, including area code)

Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under any of the following provisions:

o Written communications pursuant to Rule 425 under the Securities Act (17 CFR 230.425)

o Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17 CFR 240.14a-12)

o Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17 CFR 240.14d-2(b))

o Pre-commencement communications pursuant to Rule 13e-4(c) under the Exchange Act (17 CFR 240.13e-4(c))

ITEMS 2.02 and 7.01 RESULTS OF OPERATIONS AND FINANCIAL CONDITION AND REGULATION FD DISCLOSURE

Comerica Incorporated (“Comerica”) today released its earnings for the quarter ended March 31, 2010.  A copy of the press release and the presentation slides which will be discussed in Comerica’s webcast earnings call are attached hereto as Exhibits 99.1 and 99.2, respectively.

The information in this report (including Exhibits 99.1 and 99.2 hereto) is being is being “furnished” and shall not be deemed “filed” for the purposes of Section 18 of the Securities Exchange Act of 1934, as amended, is not subject to the liabilities of that section and is not deemed incorporated by reference in any filing under the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended, except as shall be expressly set forth by specific reference in such a filing.

ITEM 9.01FINANCIAL STATEMENTS AND EXHIBITS

(d) Exhibits

99.1Press Release dated April 21, 2010

99.2Earnings 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 hereunto 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 21, 2010

EXHIBIT INDEX

Exhibit No.	Description
99.1	Press Release dated April 21, 2010
99.2	Earnings Presentation Slides

EX-99.1

Exhibit 99.1

COMERICA REPORTS FIRST QUARTER 2010 RESULTS

Continued Improvement in Credit Quality
Significant Declines in Net Charge-offs, Provision for Loan Losses

Net Interest Margin Expands 24 Basis Points

Full Preferred Stock Redemption and Preferred Dividends Reduce Earnings by 79 Cents Per Share

Strong Capital and Liquidity to Support Future Growth

DALLAS/April 21, 2010 — Comerica Incorporated (NYSE: CMA) today reported first quarter 2010 net income of $52 million, compared to a net loss of $29 million for the fourth quarter 2009.  After preferred dividends on the fully redeemed $2.25 billion of preferred stock issued to the U.S. Treasury under its Capital Purchase Program of $123 million, or $0.79 per share, the net loss attributable to common shares was $71 million, or $0.46 per diluted common share, compared to a net loss per diluted common share of $0.42 for the fourth quarter 2009.  Preferred dividends included $24 million of cash dividends, non-cash discount accretion of $5 million and a one-time, non-cash charge of $94 million related to the full redemption of the preferred stock in March 2010. First quarter 2010 net income also included a $17 million after-tax gain from the cash settlement of a note receivable related to the 2006 sale of an investment advisory subsidiary, recorded in “income from discontinued operations, net of tax.”

(dollar amounts in millions, except per share data)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income	$	415		$	396		$	384
Provision for loan losses	175			256			203
Noninterest income	194			214			223
Noninterest expenses	404			425			397
Income (loss) from continuing operations, net of tax	35			(29		)	8
Income from discontinued operations, net of tax	17			—			1
Net income (loss)	52			(29		)	9
Preferred stock dividends to U.S. Treasury (a)	123			33			33
Net loss attributable to common shares	(71		)	(62		)	(24		)
Diluted loss per common share	(0.46		)	(0.42		)	(0.16		)
Tier 1 capital ratio	10.40		% (b)	12.46		%	11.06		%
Tangible common equity ratio (c)	9.68			7.99			7.27
Net interest margin	3.18			2.94			2.53

(a) First quarter 2010 included non-cash charges of $99 million.

(b) March 31, 2010 ratio is estimated.

(c) See Reconciliation of Non-GAAP Financial Measures.

“The encouraging signs we saw in the fourth quarter of 2009 continued in the first quarter of 2010,” said Ralph W. Babb Jr., chairman and chief executive officer.  “Our credit quality continued to improve, reflecting the strong credit underwriting and processes we have in place.  Our net interest margin expanded further in the first quarter.  We fully redeemed the preferred stock issued to the U.S. Treasury and with our solid capital position and strong liquidity are ideally positioned for future growth.  We have a consistent strategy for success that is based on relationships and skill, with a dedicated workforce to deliver the quality products and services that are our hallmark.

- more -

“Our customers continue to convey a more positive and upbeat tone, and this is reflected in the increased number of loans in the pipeline.  The decline in loan outstandings we saw in the fourth quarter of 2009 slowed further in the first quarter of 2010, and the pace of decline moderated in each successive month of the first quarter. All of these positive trends lead us to believe our operating fundamentals will show improvement in 2010.  We are moving forward with confidence in our people and our ability to grow as the economy continues its recovery.”

First Quarter 2010 Highlights Compared to Fourth Quarter 2009

·Net interest income increased five percent, or $19 million, to $415 million for the first quarter 2010 compared to $396 million for the fourth quarter 2009. The net interest margin of 3.18 percent increased 24 basis points, from 2.94 percent in the fourth quarter 2009.

·Net credit-related charge-offs decreased $52 million to $173 million, or 1.68 percent of average total loans, for the first quarter 2010, compared to $225 million, or 2.10 percent of average total loans, for the fourth quarter 2009.

·The provision for credit losses decreased $77 million to $182 million for the first quarter 2010, compared to $259 million for the fourth quarter 2009.

·In March 2010, Comerica fully redeemed $2.25 billion of preferred stock issued to the U.S. Treasury. The redemption was funded by the net proceeds from an $880 million common stock offering completed in March 2010 and from excess liquidity at the parent company. Liquidity at the parent company remained strong after the redemption of the preferred stock.

·The tangible common equity ratio was 9.68 percent at March 31, 2010, an increase of 169 basis points from December 31, 2009. The estimated Tier 1 common ratio was 9.58 percent and the estimated Tier 1 capital ratio was 10.40 percent at March 31, 2010, an increase of 140 basis points and a decrease of 206 basis points, respectively, from December 31, 2009.

2

Net Interest Income and Net Interest Margin

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income	$	415		$	396		$	384
Net interest margin	3.18		%	2.94		%	2.53		%
Selected average balances:
Total earning assets	$	52,941		$	53,953		$	61,752
Total investment securities	7,382			8,587			10,126
Federal Reserve Bank deposits (excess liquidity) (a)	4,092			2,453			1,812
Total loans	41,313			42,753			49,556
Total core deposits (b)	37,236			36,742			33,832
Total noninterest-bearing deposits	14,624			14,430			11,364

(a) See Reconciliation of Non-GAAP Financial Measures.

(b) Core deposits exclude other time deposits and foreign office time deposits.

·The $19 million increase in net interest income in the first quarter 2010, when compared to fourth quarter 2009, resulted primarily from an increase in the net interest margin.

·The net interest margin of 3.18 percent increased 24 basis points, compared to fourth quarter 2009, primarily from improved loan spreads, a less costly blend of core deposits, and maturing higher-cost wholesale funding. The net interest margin was reduced by approximately 24 basis points in the first quarter 2010 from excess liquidity, which was represented by $4.1 billion of average balances deposited with the Federal Reserve Bank, compared to a reduction of 13 basis points from $2.5 billion of average balances in the fourth quarter 2009. At March 31, 2010, excess liquidity was represented by $3.8 billion of balances deposited with the Federal Reserve Bank, compared to $4.8 billion at December 31, 2009.

·Average earning assets decreased $1.0 billion, due to a $1.4 billion decrease in average loans, partially offset by an increase of $428 million in other earning assets. The decline in loans of $1.4 billion in the first quarter 2010 continued to slow, compared to declines of $2.0 billion and $2.9 billion in the fourth quarter and third quarters of 2009, respectively, and reflected subdued demand from customers in a modestly recovering economic environment.

·First quarter 2010 average core deposits increased $494 million compared to fourth quarter 2009, including a $942 million increase in money market and NOW deposits and a $194 million increase in noninterest-bearing deposits, partially offset by a $650 million decrease in higher-cost customer certificates of deposit.

Noninterest Income

Noninterest income was $194 million for the first quarter 2010, compared to $214 million for the fourth quarter 2009. The $20 million decrease in noninterest income in the first quarter 2010, compared to the fourth quarter 2009, reflected an $8 million decrease in net securities gains, a $6 million decrease in gains related to the repurchase of debt and small decreases in several categories of noninterest income.

3

Noninterest Expenses

Noninterest expenses were $404 million for the first quarter 2010, compared to $425 million for the fourth quarter 2009. The $21 million decrease in noninterest expenses in the first quarter 2010, compared to the fourth quarter 2009, was primarily due to decreases in other real estate expense ($10 million), pension expense ($9 million) and salaries expense ($5 million), partially offset by an increase in the provision for credit losses on lending-related commitments ($4 million).  Full-time equivalent staff decreased by approximately 115 employees from December 31, 2009 and 481 employees, or five percent, from March 31, 2009.  Certain categories of noninterest expenses are highlighted in the table below.

	1st Qtr ‘10		4th Qtr ‘09		1st Qtr ‘09
Salaries	$	169	$	174	$	171
Employee benefits
Pension expense	5		14		16
Other benefits	39		37		39
Total employee benefits	44		51		55
Other real estate expense	12		22		7
Provision for credit losses on lending-related commitments	7		3		(1		)

Discontinued Operations

Income from discontinued operations in the first quarter 2010 included a $17 million after-tax gain resulting from a successfully negotiated cash settlement of a note receivable related to the 2006 sale of Munder Capital Management, an investment advisor. The cash received of $35 million paid the note in full and concluded our commitments and financial arrangements with Munder.

Credit Quality

“We were pleased that credit quality improved at a faster pace than we had expected.  This reflects our continued efforts to quickly and proactively identify and work through problem loans.  We saw broad-based improvement in credit quality across all business lines, including significant declines in net charge-offs and provision for loan losses.  The Commercial Real Estate business line experienced an increase in net charge-offs but saw declines in nonperforming and watch list loans.  We have updated our credit outlook for full-year 2010 to reflect the significant improvement we saw in the first quarter.”

4

·The provision for loan losses decreased $81 million, with declines in all major markets.

·Net loan charge-offs decreased $51 million to $173 million in the first quarter 2010, from $224 million in the fourth quarter 2009. Excluding the Commercial Real Estate business line, net loan charge-offs decreased $75 million, primarily in the Middle Market and Global Corporate Banking business lines. Net loan charge-offs in the Commercial Real Estate business line in the first quarter 2010 increased to $86 million, from $62 million in the fourth quarter 2009, with increases in the Texas, Florida and Other markets partially offset by decreases in the Midwest and Western markets.

·Nonperforming assets decreased $41 million to $1.3 billion, or 3.06 percent of total loans and foreclosed property, at March 31, 2010.

·During the first quarter 2010, $245 million of loan relationships greater than $2 million were transferred to nonaccrual status, a decrease of $21 million from the fourth quarter 2009.  Of the transfers of loan relationships greater than $2 million to nonaccrual in the first quarter 2010, $129 million were in the Commercial Real Estate business line and $63 million were in Middle Market.

·Nonaccrual loans were charged down 44 percent as of March 31, 2010 and December 31, 2009, compared to 36 percent one year ago.

·Foreclosed property decreased $22 million to $89 million at March 31, 2010, from $111 million at December 31, 2009.

·Loans past due 90 days or more and still accruing were $83 million at March 31, 2010, a decrease of $18 million compared to December 31, 2009.

·The allowance for loan losses to total loans ratio increased to 2.42 percent at March 31, 2010, from 2.34 percent at December 31, 2009.

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net loan charge-offs	$	173		$	224		$	157
Net lending-related commitment charge-offs	—			1			—
Total net credit-related charge-offs	173			225			157
Net loan charge-offs/Average total loans	1.68		%	2.09		%	1.26		%
Net credit-related charge-offs/Average total loans	1.68			2.10			1.26
Provision for loan losses	$	175		$	256		$	203
Provision for credit losses on lending-related commitments	7			3			(1		)
Total provision for credit losses	182			259			202
Nonperforming loans	1,162			1,181			982
Nonperforming assets (NPAs)	1,251			1,292			1,073
NPAs/Total loans and foreclosed property	3.06		%	3.06		%	2.20		%
Loans past due 90 days or more and still accruing	$	83		$	101		$	207
Allowance for loan losses	987			985			816
Allowance for credit losses on lending-related commitments (a)	44			37			37
Total allowance for credit losses	1,031			1,022			853
Allowance for loan losses/Total loans	2.42		%	2.34		%	1.68		%
Allowance for loan losses/Nonperforming loans	85			83			83

(a) Included in “Accrued expenses and other liabilities” on the consolidated balance sheets.

5

Balance Sheet and Capital Management

Total assets and common shareholders’ equity were $57.1 billion and $5.7 billion, respectively, at March 31, 2010, compared to $59.2 billion and $4.9 billion, respectively, at December 31, 2009. There were approximately 176 million common shares outstanding at March 31, 2010.

In March 2010, Comerica fully redeemed $2.25 billion of preferred stock issued to the U.S. Treasury. The redemption was partially funded by the net proceeds from an $880 million common stock offering. Preferred stock dividends in the first quarter 2010 included cash dividends of $24 million, non-cash discount accretion of $5 million and a one-time, non-cash redemption charge of $94 million, reflecting the accelerated accretion of the remaining discount. Comerica elected not to repurchase a related warrant for 11.5 million shares of common stock issued to the U.S. Treasury.

Comerica’s tangible common equity ratio was 9.68 percent at March 31, 2010, an increase of 169 basis points from December 31, 2009. The estimated Tier 1 common ratio was 9.58 percent and the estimated Tier 1 capital ratio was 10.40 percent at March 31, 2010, an increase of 140 basis points and a decrease of 206 basis points, respectively, from December 31, 2009.  The increase in the tangible common equity ratio and the estimated Tier 1 common ratio reflected the increase in common shareholders’ equity from the common stock offering, while the decrease in the estimated Tier 1 capital ratio reflected the net decrease in total shareholders’ equity after the redemption of the preferred stock.

Full-Year 2010 Outlook

For full-year 2010, management expects the following, based on a modestly improving economic environment.

·Management expects low single-digit loan growth from period-end March 31, 2010 to period-end December 31, 2010.  Investment securities are expected to remain at a level similar to March 31, 2010.

·Based on no increase in the Federal Funds rate, management expects an average net interest margin between 3.25 percent and 3.35 percent for full-year 2010, reflecting the benefit, compared to 2009, from improved loan pricing, lower funding costs and a lower level of excess liquidity.

·Management expects net credit-related charge-offs between $675 million and $725 million for full-year 2010. The provision for credit losses is expected to be consistent with net credit-related charge-offs.

·Management expects flat to low single-digit decline in noninterest income compared to 2009, after excluding $243 million of 2009 net securities gains.

·Management expects a low single-digit decrease in noninterest expenses compared to 2009.

·Management expects income tax expense to approximate 35 percent of income before income taxes less approximately $60 million of permanent differences related to low-income housing and bank-owned life insurance.

6

Business Segments

Comerica’s continuing operations are strategically aligned into three major business segments: the Business Bank, the Retail Bank, and Wealth & Institutional Management.  The Finance Division also is included as a segment. The financial results below are based on the internal business unit structure of the Corporation and methodologies in effect at March 31, 2010 and are presented on a fully taxable equivalent (FTE) basis. The accompanying narrative addresses first quarter 2010 results compared to fourth quarter 2009.

The following table presents net income (loss) by business segment.

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Business Bank	$	89		$	65		$	56
Retail Bank	(7		)	(12		)	(7		)
Wealth & Institutional Management	11			5			13
	93			58			62
Finance	(59		)	(62		)	(50		)
Other (a)	18			(25		)	(3		)
Total	$	52		$	(29	)	$	9

(a) Includes discontinued operations and items not directly associated with the three major business segments or the Finance Division.

Business Bank

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	341		$	343		$	312
Provision for loan losses	137			179			177
Noninterest income	76			77			93
Noninterest expenses	162			165			157
Net income	89			65			56
Net credit-related charge-offs	137			183			123
Selected average balances:
Assets	31,293			32,655			39,505
Loans	30,918			32,289			38,527
Deposits	17,750			16,944			14,040
Net interest margin	4.48		%	4.21		%	3.28		%

·Average loans decreased $1.4 billion, reflecting declines across all markets and all business lines except National Dealer Services. The decline in loans slowed in the first quarter 2010.

·Average deposits increased $806 million, reflecting increases across all markets, primarily in Global Corporate Banking, Commercial Real Estate and Mortgage Banker Finance.

·The net interest margin of 4.48 percent increased 27 basis points, primarily due to an increase in loan spreads and an increase in noninterest-bearing deposits.

·The provision for loan losses decreased $42 million, reflecting decreases in most business lines, partially offset by increases in Middle Market and Commercial Real Estate.

·Noninterest expenses decreased $3 million, primarily due to decreases in other real estate and salaries and employee benefits expense, partially offset by an increase in the provision for credit losses on lending-related commitments.

7

Retail Bank

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	130		$	129		$	126
Provision for loan losses	31			36			23
Noninterest income	44			48			46
Noninterest expenses	154			161			161
Net loss	(7		)	(12		)	(7		)
Net credit-related charge-offs	26			30			26
Selected average balances:
Assets	6,106			6,257			6,875
Loans	5,599			5,733			6,284
Deposits	16,718			17,020			17,391
Net interest margin	3.18		%	3.02		%	2.93		%

·Average loans decreased $134 million, across all markets. The decline in loans slowed in the first quarter 2010.

·Average deposits decreased $302 million, primarily in the Midwest market, reflecting a decrease in higher-cost customer certificates of deposit, partially offset by an increase in money market and NOW deposits.

·The net interest margin of 3.18 percent increased 16 basis points, due to an increase in loan spreads and an increase in deposit spreads related to maturing higher-cost customer certificates of deposit and an increase in NOW balances.

·The provision for loan losses decreased $5 million.

·Noninterest income decreased $4 million, primarily due to decreased service charges on deposit accounts.

·Noninterest expenses decreased $7 million, primarily due to decreases in salaries and employee benefits expense and other real estate expense.

Wealth and Institutional Management

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	42		$	42		$	36
Provision for loan losses	12			19			10
Noninterest income	60			60			70
Noninterest expenses	73			76			75
Net income	11			5			13
Net credit-related charge-offs	10			12			8
Selected average balances:
Assets	4,862			4,841			4,870
Loans	4,789			4,746			4,750
Deposits	2,791			2,849			2,429
Net interest margin	3.53		%	3.50		%	3.11		%

·Average loans increased $43 million.

·Average deposits decreased $58 million, primarily in the Western market, reflecting decreases in noninterest-bearing deposits, money market deposits and higher-cost customer certificates of deposit, partially offset by an increase in NOW deposits.

·The net interest margin of 3.53 percent increased three basis points, primarily due to increases in loan and deposit spreads.

·The provision for loan losses decreased $7 million.

·Noninterest expenses decreased $3 million, primarily due to a decrease in salaries and employee benefits expense.

8

Geographic Market Segments

Comerica also provides market segment results for four primary geographic markets: Midwest, Western, Texas and Florida.  In addition to the four primary geographic markets, Other Markets and International are also reported as market segments.  The financial results below are based on methodologies in effect at March 31, 2010 and are presented on a fully taxable equivalent (FTE) basis. The accompanying narrative addresses first quarter 2010 results compared to fourth quarter 2009.

The following table presents net income (loss) by market segment.

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Midwest	$	26		$	12		$	29
Western	22			7			(7		)
Texas	14			13			15
Florida	1			3			(6		)
Other Markets	16			23			22
International	14			—			9
	93			58			62
Finance & Other Businesses (a)	(41		)	(87		)	(53		)
Total	$	52		$	(29	)	$	9

(a) Includes discontinued operations and items not directly associated with the geographic markets.

Midwest Market

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	205		$	205		$	194
Provision for loan losses	81			101			83
Noninterest income	102			106			127
Noninterest expenses	186			194			194
Net income	26			12			29
Net credit-related charge-offs	55			97			54
Selected average balances:
Assets	15,573			16,090			19,139
Loans	15,332			15,811			18,267
Deposits	17,068			17,200			16,697
Net interest margin	4.86		%	4.73		%	4.30		%

·Average loans decreased $479 million, reflecting declines across most business lines. The decline in loans slowed in the first quarter 2010.

·Average deposits decreased $132 million, due to a decrease in the Retail Bank, partially offset by an increase in Global Corporate Banking.

·The net interest margin of 4.86 percent increased 13 basis points, primarily due to an increase in loan spreads and an increase in deposit spreads related to maturing higher-cost customer certificates of deposit and an increase in money market and NOW deposits.

·The provision for loan losses decreased $20 million, primarily due to decreases in Leasing and Personal Banking.

·Noninterest income decreased $4 million, reflecting small decreases in several categories.

·Noninterest expenses decreased $8 million, due to decreases in salaries and employee benefits expense and other real estate expense, partially offset by an increase in the provision for credit losses on lending-related commitments.

9

Western Market

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	161		$	163		$	146
Provision for loan losses	59			79			88
Noninterest income	36			33			36
Noninterest expenses	105			110			104
Net income (loss)	22			7			(7		)
Net credit-related charge-offs	64			85			76
Selected average balances:
Assets	13,175			13,484			15,443
Loans	12,980			13,289			15,253
Deposits	11,927			11,899			10,640
Net interest margin	5.04		%	4.85		%	3.91		%

·Average loans decreased $309 million, primarily due to declines in Commercial Real Estate, Technology and Life Sciences and Middle Market.  The decline in loans slowed in the first quarter 2010.

·Average deposits increased $28 million, primarily due to increases in Commercial Real Estate and Technology and Life Sciences, partially offset by a decrease in the Financial Services Division.

·The net interest margin of 5.04 percent increased 19 basis points, primarily due to an increase in loan spreads and an increase in deposit spreads related to maturing higher-cost customer certificates of deposit and an increase in NOW balances.

·The provision for loan losses decreased $20 million, reflecting decreases in Global Corporate Banking, Commercial Real Estate, Technology and Life Sciences, National Dealer Services and Leasing, partially offset by increased provisions for Middle Market, Specialty Businesses and Personal Banking.

·Noninterest income increased $3 million, primarily due to an increase in commercial lending fees

·Noninterest expenses decreased $5 million, primarily due to decreases in other real estate expense, net occupancy expense and salaries and employee benefits expense.

Texas Market

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	79		$	78		$	70
Provision for loan losses	17			20			9
Noninterest income	20			23			21
Noninterest expenses	60			61			58
Net income	14			13			15
Total net credit-related charge-offs	25			13			8
Selected average balances:
Assets	6,892			7,118			8,069
Loans	6,704			6,934			7,847
Deposits	4,957			4,737			4,198
Net interest margin	4.79		%	4.46		%	3.62		%

·Average loans decreased $230 million, reflecting declines across all business lines.  The decline in loans slowed in the first quarter 2010.

·Average deposits increased $220 million, primarily due to an increase in Global Corporate Banking.

·The net interest margin of 4.79 percent increased 33 basis points, primarily due to an increase in loan and deposit spreads and the benefit provided by an increase in noninterest-bearing and NOW deposits.

·The provision for loan losses decreased $3 million, due to declines in Middle Market and Energy Lending, partially offset by an increase in Commercial Real Estate.

·Noninterest income decreased $3 million, partially due to a decrease in commercial lending fees.

10

Florida Market

(dollar amounts in millions)	1st Qtr ‘10			4th Qtr ‘09			1st Qtr ‘09
Net interest income (FTE)	$	10		$	10		$	11
Provision for loan losses	3			—			15
Noninterest income	3			3			3
Noninterest expenses	9			9			8
Net income (loss)	1			3			(6		)
Net credit-related charge-offs	10			4			12
Selected average balances:
Assets	1,576			1,608			1,869
Loans	1,576			1,613			1,878
Deposits	361			333			253
Net interest margin	2.54		%	2.57		%	2.31		%

·Average loans decreased $37 million, primarily due to a decrease in Middle Market.  The decline in loans slowed in the first quarter 2010.

·Average deposits increased $28 million, primarily due to an increase in Global Corporate Banking.

·The net interest margin of 2.54 percent decreased three basis points.

·The provision for loan losses increased $3 million, primarily due to increases in Commercial Real Estate and Middle Market, partially offset by a decrease in Private Banking.

Conference Call and Webcast

Comerica will host a conference call to review first quarter 2010 financial results at 7 a.m. CT Wednesday, April 21, 2010. Interested parties may access the conference call by calling (800) 309-2262 or (706) 679-5261 (event ID No. 63304761). The call and supplemental financial information can also be accessed on the Internet at www.comerica.com.  A replay will be available approximately two hours following the conference call through April 30, 2010. The conference call replay can be accessed by calling (800) 642-1687 or (706) 645-9291 (event ID No. 63304761). A replay of the Webcast can also be accessed via Comerica’s “Investor Relations” page at www.comerica.com.

Comerica Incorporated is a financial services company headquartered in Dallas, Texas, and strategically aligned by three major business segments: the Business Bank, the Retail Bank, and Wealth & Institutional Management. Comerica focuses on relationships and helping people and businesses be successful. In addition to Texas, Comerica Bank locations can be found in Arizona, California, Florida and Michigan, with select businesses operating in several other states, as well as in Canada and Mexico.

This press release contains both financial measures based on accounting principles generally accepted in the United States (GAAP) and non-GAAP based financial measures, which are used where management believes it to be helpful in understanding Comerica’s results of operations or financial position.  Where non-GAAP financial measures are used, the comparable GAAP financial measure, as well as the reconcilement to the comparable GAAP financial measure, can be found in this press release.  These disclosures should not be viewed as a substitute for operating results determined in accordance with GAAP, nor are they necessarily comparable to non-GAAP performance measures that may be presented by other companies.

11

Forward-looking Statements

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 “anticipates,” “believes,” “feels,” “expects,” “estimates,” “seeks,” “strives,” “plans,” “intends,” “outlook,” “forecast,” “position,” “target,” “mission,” “assume,” “achievable,” “potential,” “strategy,” “goal,” “aspiration,” “outcome,” “continue,” “remain,” “maintain,” “trend,” “objective” and variations of such words and similar expressions, or future or conditional verbs such as “will,” “would,” “should,” “could,” “might,” “can,” “may” or similar expressions, as they relate to Comerica or its management, are intended to identify forward-looking statements. These forward-looking statements are predicated on the beliefs and assumptions of Comerica’s management 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, Comerica’s actual results could differ materially from those discussed.  Factors that could cause or contribute to such differences are further economic downturns, changes in the pace of an economic recovery and related changes in employment levels, changes in real estate values, fuel prices, energy costs or other events that could affect customer income levels or general economic conditions, the effects of recently enacted legislation, actions taken by or proposed by the U.S. Department of Treasury, the Board of Governors of the Federal Reserve System, the Texas Department of Banking and the Federal Deposit Insurance Corporation, legislation enacted in the future, and the impact and expiration of such legislation and regulatory actions, the effects of war and other armed conflicts or acts of terrorism, the effects of natural disasters including, but not limited to, hurricanes, tornadoes, earthquakes, fires, droughts and floods, the disruption of private or public utilities, the implementation of Comerica’s strategies and business models, management’s ability to maintain and expand customer relationships, changes in customer borrowing, repayment, investment and deposit practices, management’s ability to retain key officers and employees, changes in the accounting treatment of any particular item, the impact of regulatory examinations, declines or other changes in the businesses or industries in which Comerica has a concentration of loans, including, but not limited to, the automotive production industry and the real estate business lines, the anticipated performance of any new banking centers, the entry of new competitors in Comerica’s markets, changes in the level of fee income, changes in applicable laws and regulations, including those concerning taxes, banking, securities and insurance, changes in trade, monetary and fiscal policies, including the interest rate policies of the Board of Governors of the Federal Reserve System, fluctuations in inflation or interest rates, changes in general economic, political or industry conditions and related credit and market conditions, the interdependence of financial service companies and adverse conditions in the stock market. Comerica cautions that the foregoing list of factors is not exclusive. For discussion of factors that may cause actual results to differ from expectations, please refer to our filings with the Securities and Exchange Commission. In particular, please refer to “Item 1A. Risk Factors” beginning on page 11 of Comerica’s Annual Report on Form 10-K for the year ended December 31, 2009. 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 Contact:	Investor Contacts:
Wayne J. Mielke	Darlene P. Persons
(214) 462-4463	(214) 462-6831
	Tracy Fralick
	(214) 462-6834

12

CONSOLIDATED FINANCIAL HIGHLIGHTS (unaudited)

Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31,			December 31,			March 31,
(in millions, except per share data)	2010			2009			2009
PER COMMON SHARE AND COMMON STOCK DATA
Diluted net loss	$	(0.46	)	$	(0.42	)	$	(0.16	)
Cash dividends declared	0.05			0.05			0.05
Common shareholders’ equity (at period end)	32.15			32.27			33.40
Average diluted shares (in thousands)	155,155			149,445			149,257
KEY RATIOS
Return on average common shareholders’ equity	(5.61		)%	(5.10		)%	(1.90		)%
Return on average assets	0.36			(0.19		)	0.06
Tier 1 common capital ratio (a) (b)	9.58			8.18			7.32
Tier 1 risk-based capital ratio (b)	10.40			12.46			11.06
Total risk-based capital ratio (b)	14.93			16.93			15.36
Leverage ratio (b)	11.00			13.25			11.65
Tangible common equity ratio (a)	9.68			7.99			7.27
AVERAGE BALANCES
Commercial loans	$	21,015		$	21,971		$	27,180
Real estate construction loans	3,386			3,703			4,510
Commercial mortgage loans	10,387			10,393			10,431
Residential mortgage loans	1,632			1,664			1,846
Consumer loans	2,481			2,517			2,574
Lease financing	1,130			1,181			1,300
International loans	1,282			1,324			1,715
Total loans	41,313			42,753			49,556
Earning assets	52,941			53,953			61,752
Total assets	57,519			58,396			66,737
Noninterest-bearing deposits	14,624			14,430			11,364
Interest-bearing core deposits	22,612			22,312			22,468
Total core deposits	37,236			36,742			33,832
Common shareholders’ equity	5,070			4,876			5,024
Total shareholders’ equity	6,864			7,024			7,155
NET INTEREST INCOME
Net interest income (fully taxable equivalent basis)	$	416		$	398		$	386
Fully taxable equivalent adjustment	1			2			2
Net interest margin	3.18		%	2.94		%	2.53		%
CREDIT QUALITY
Nonaccrual loans	$	1,145		$	1,165		$	982
Reduced-rate loans	17			16			—
Total nonperforming loans	1,162			1,181			982
Foreclosed property	89			111			91
Total nonperforming assets	1,251			1,292			1,073
Loans past due 90 days or more and still accruing	83			101			207
Gross loan charge-offs	184			232			161
Loan recoveries	11			8			4
Net loan charge-offs	173			224			157
Lending-related commitment charge-offs	—			1			—
Total net credit-related charge-offs	173			225			157
Allowance for loan losses	987			985			816
Allowance for credit losses on lending-related commitments	44			37			37
Total allowance for credit losses	1,031			1,022			853
Allowance for loan losses as a percentage of total loans	2.42		%	2.34		%	1.68		%
Net loan charge-offs as a percentage of average total loans	1.68			2.09			1.26
Net credit-related charge-offs as a percentage of average total loans	1.68			2.10			1.26
Nonperforming assets as a percentage of total loans and foreclosed property	3.06			3.06			2.20
Allowance for loan losses as a percentage of total nonperforming loans	85			83			83

(a) See Reconciliation of Non-GAAP Financial Measures.

(b) March 31, 2010 ratios are estimated.

13

CONSOLIDATED BALANCE SHEETS (unaudited)

Comerica Incorporated and Subsidiaries

	March 31,			December 31,			March 31,
(in millions, except share data)	2010			2009			2009
ASSETS
Cash and due from banks	$	769		$	774		$	952
Interest-bearing deposits with banks	3,860			4,843			2,558
Other short-term investments	165			138			248
Investment securities available-for-sale	7,346			7,416			10,844
Commercial loans	20,756			21,690			26,431
Real estate construction loans	3,202			3,461			4,379
Commercial mortgage loans	10,358			10,457			10,514
Residential mortgage loans	1,631			1,651			1,836
Consumer loans	2,472			2,511			2,577
Lease financing	1,120			1,139			1,232
International loans	1,306			1,252			1,655
Total loans	40,845			42,161			48,624
Less allowance for loan losses	(987		)	(985		)	(816		)
Net loans	39,858			41,176			47,808
Premises and equipment	637			644			676
Customers’ liability on acceptances outstanding	21			11			10
Accrued income and other assets	4,450			4,247			4,274
Total assets	$	57,106		$	59,249		$	67,370
LIABILITIES AND SHAREHOLDERS’ EQUITY
Noninterest-bearing deposits	$	15,290		$	15,871		$	12,645
Money market and NOW deposits	16,009			14,450			12,240
Savings deposits	1,462			1,342			1,328
Customer certificates of deposit	5,979			6,413			8,815
Other time deposits	814			1,047			6,372
Foreign office time deposits	412			542			494
Total interest-bearing deposits	24,676			23,794			29,249
Total deposits	39,966			39,665			41,894
Short-term borrowings	489			462			2,207
Acceptances outstanding	21			11			10
Accrued expenses and other liabilities	1,047			1,022			1,464
Medium- and long-term debt	9,915			11,060			14,612
Total liabilities	51,438			52,220			60,187
Fixed rate cumulative perpetual preferred stock, series F,no par value, $1,000 liquidation value per share:
Authorized - 2,250,000 shares at 12/31/09 and 3/31/09
Issued - 2,250,000 shares at 12/31/09 and 3/31/09	—			2,151			2,134
Common stock - $5 par value:
Authorized - 325,000,000 shares
Issued - 203,878,110 shares at 3/31/10 and 178,735,252 shares at 12/31/09 and 3/31/09	1,019			894			894
Capital surplus	1,468			740			727
Accumulated other comprehensive loss	(303		)	(336		)	(238		)
Retained earnings	5,064			5,161			5,252
Less cost of common stock in treasury - 27,575,283 shares at 3/31/10, 27,555,623 shares at 12/31/09 and 27,580,899 shares at 3/31/09	(1,580		)	(1,581		)	(1,586		)
Total shareholders’ equity	5,668			7,029			7,183
Total liabilities and shareholders’ equity	$	57,106		$	59,249		$	67,370

14

CONSOLIDATED STATEMENTS OF INCOME (unaudited)

Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31,
(in millions, except per share data)	2010			2009
INTEREST INCOME
Interest and fees on loans	$	412		$	452
Interest on investment securities	61			109
Interest on short-term investments	3			2
Total interest income	476			563
INTEREST EXPENSE
Interest on deposits	35			125
Interest on short-term borrowings	—			2
Interest on medium- and long-term debt	26			52
Total interest expense	61			179
Net interest income	415			384
Provision for loan losses	175			203
Net interest income after provision for loan losses	240			181
NONINTEREST INCOME
Service charges on deposit accounts	56			58
Fiduciary income	39			42
Commercial lending fees	22			18
Letter of credit fees	18			16
Card fees	13			12
Foreign exchange income	10			9
Bank-owned life insurance	8			8
Brokerage fees	6			9
Net securities gains	2			13
Other noninterest income	20			38
Total noninterest income	194			223
NONINTEREST EXPENSES
Salaries	169			171
Employee benefits	44			55
Total salaries and employee benefits	213			226
Net occupancy expense	42			41
Equipment expense	17			16
Outside processing fee expense	23			25
Software expense	22			20
FDIC insurance expense	17			15
Other real estate expense	12			7
Legal fees	9			7
Litigation and operational losses	1			2
Provision for credit losses on lending-related commitments	7			(1		)
Other noninterest expenses	41			39
Total noninterest expenses	404			397
Income from continuing operations before income taxes	30			7
Provision (benefit) for income taxes	(5		)	(1		)
Income from continuing operations	35			8
Income from discontinued operations, net of tax	17			1
NET INCOME	52			9
Preferred stock dividends	123			33
Income allocated to participating securities	—			—
Net loss attributable to common shares	$	(71	)	$	(24	)
Basic earnings per common share:
Loss from continuing operations	$	(0.57	)	$	(0.17	)
Net loss	(0.46		)	(0.16		)
Diluted earnings per common share:
Loss from continuing operations	(0.57		)	(0.17		)
Net loss	(0.46		)	(0.16		)
Cash dividends declared on common stock	9			7
Cash dividends declared per common share	0.05			0.05

15

CONSOLIDATED QUARTERLY STATEMENTS OF INCOME (unaudited)

Comerica Incorporated and Subsidiaries

	First			Fourth			Third			Second			First			First Quarter 2010 Compared To:
	Quarter			Quarter			Quarter			Quarter			Quarter			Fourth Quarter 2009						First Quarter 2009
(in millions, except per share data)	2010			2009			2009			2009			2009			Amount			Percent			Amount			Percent
INTEREST INCOME
Interest and fees on loans	$	412		$	424		$	444		$	447		$	452		$	(12	)	(3		)%	$	(40	)	(9	)%
Interest on investment securities	61			53			64			103			109			8			16			(48		)	(44	)
Interest on short-term investments	3			2			3			2			2			1			49			1			74
Total interest income	476			479			511			552			563			(3		)	(1		)	(87		)	(15	)
INTEREST EXPENSE
Interest on deposits	35			52			89			106			125			(17		)	(30		)	(90		)	(72	)
Interest on short-term borrowings	—			—			—			—			2			—			27			(2		)	(96	)
Interest on medium- and long-term debt	26			31			37			44			52			(5		)	(19		)	(26		)	(51	)
Total interest expense	61			83			126			150			179			(22		)	(26		)	(118		)	(66	)
Net interest income	415			396			385			402			384			19			5			31			8
Provision for loan losses	175			256			311			312			203			(81		)	(32		)	(28		)	(14	)
Net interest income after provision for loan losses	240			140			74			90			181			100			71			59			32
NONINTEREST INCOME
Service charges on deposit accounts	56			56			59			55			58			—			—			(2		)	(3	)
Fiduciary income	39			38			40			41			42			1			1			(3		)	(7	)
Commercial lending fees	22			21			21			19			18			1			2			4			21
Letter of credit fees	18			19			18			16			16			(1		)	(3		)	2			18
Card fees	13			14			13			12			12			(1		)	(1		)	1			14
Foreign exchange income	10			11			10			11			9			(1		)	(7		)	1			4
Bank-owned life insurance	8			9			8			10			8			(1		)	(9		)	—			—
Brokerage fees	6			7			7			8			9			(1		)	(15		)	(3		)	(35	)
Net securities gains	2			10			107			113			13			(8		)	(81		)	(11		)	(86	)
Other noninterest income	20			29			32			13			38			(9		)	(33		)	(18		)	(48	)
Total noninterest income	194			214			315			298			223			(20		)	(9		)	(29		)	(13	)
NONINTEREST EXPENSES
Salaries	169			174			171			171			171			(5		)	(3		)	(2		)	(1	)
Employee benefits	44			51			51			53			55			(7		)	(14		)	(11		)	(20	)
Total salaries and employee benefits	213			225			222			224			226			(12		)	(6		)	(13		)	(6	)
Net occupancy expense	42			43			40			38			41			(1		)	(2		)	1			2
Equipment expense	17			16			15			15			16			1			6			1			5
Outside processing fee expense	23			23			24			25			25			—			—			(2		)	(8	)
Software expense	22			23			21			20			20			(1		)	(3		)	2			10
FDIC insurance expense	17			15			15			45			15			2			11			2			11
Other real estate expense	12			22			10			9			7			(10		)	(45		)	5			80
Legal fees	9			12			8			10			7			(3		)	(27		)	2			18
Litigation and operational losses	1			3			3			2			2			(2		)	(43		)	(1		)	(33	)
Provision for credit losses on lending-related commitments	7			3			2			(4		)	(1		)	4			N/M			8			N/M
Other noninterest expenses	41			40			39			45			39			1			—			2			9
Total noninterest expenses	404			425			399			429			397			(21		)	(5		)	7			2
Income (loss) from continuing operations before income taxes	30			(71		)	(10		)	(41		)	7			101			N/M			23			N/M
Provision (benefit) for income taxes	(5		)	(42		)	(29		)	(59		)	(1		)	37			88			(4		)	N/M
Income (loss) from continuing operations	35			(29		)	19			18			8			64			N/M			27			N/M
Income from discontinued operations, net of tax	17			—			—			—			1			17			N/M			16			N/M
NET INCOME (LOSS)	52			(29		)	19			18			9			81			N/M			43			N/M
Preferred stock dividends	123			33			34			34			33			90			N/M			90			N/M
Income allocated to participating securities	—			—			1			—			—			—			—			—			—
Net loss attributable to common shares	$	(71	)	$	(62	)	$	(16	)	$	(16	)	$	(24	)	$	(9	)	$	(14	)%	$	(47	)	N/M	%
Basic earnings per common share:
Loss from continuing operations	$	(0.57	)	$	(0.42	)	$	(0.10	)	$	(0.11	)	$	(0.17	)	$	(0.15	)	(0.36		)%	$	(0.40	)	N/M	%
Net loss	(0.46		)	(0.42		)	(0.10		)	(0.11		)	(0.16		)	(0.04		)	(0.10		)	(0.30		)	N/M
Diluted earnings per common share:
Loss from continuing operations	(0.57		)	(0.42		)	(0.10		)	(0.11		)	(0.17		)	(0.15		)	(0.36		)	(0.40		)	N/M
Net loss	(0.46		)	(0.42		)	(0.10		)	(0.11		)	(0.16		)	(0.04		)	(0.10		)	(0.30		)	N/M
Cash dividends declared on common stock	9			8			7			8			7			1			17			2			18
Cash dividends declared per common share	0.05			0.05			0.05			0.05			0.05			—			—			—			—

N/M - Not meaningful

16

ANALYSIS OF THE ALLOWANCE FOR LOAN LOSSES (unaudited)

Comerica Incorporated and Subsidiaries

	2010			2009
(in millions)	1st Qtr			4th Qtr			3rd Qtr			2nd Qtr			1st Qtr
Balance at beginning of period	$	985		$	953		$	880		$	816		$	770
Loan charge-offs:
Commercial	49			113			113			88			61
Real estate construction:
Commercial Real Estate business line (a)	71			33			63			81			57
Other business lines (b)	3			—			1			—			—
Total real estate construction	74			33			64			81			57
Commercial mortgage:
Commercial Real Estate business line (a)	16			27			24			23			16
Other business lines (b)	28			25			15			23			18
Total commercial mortgage	44			52			39			46			34
Residential mortgage	2			6			11			2			2
Consumer	8			9			7			12			6
Lease financing	—			6			6			24			—
International	7			13			5			4			1
Total loan charge-offs	184			232			245			257			161
Recoveries on loans previously charged-off:
Commercial	7			7			3			5			3
Real estate construction	1			—			1			—			—
Commercial mortgage	3			1			—			2			—
Residential mortgage	—			—			—			—			—
Consumer	—			—			1			—			1
Lease financing	—			—			—			1			—
International	—			—			1			1			—
Total recoveries	11			8			6			9			4
Net loan charge-offs	173			224			239			248			157
Provision for loan losses	175			256			311			312			203
Foreign currency translation adjustment	—			—			1			—			—
Balance at end of period	$	987		$	985		$	953		$	880		$	816
Allowance for loan losses as a percentage of total loans	2.42		%	2.34		%	2.19		%	1.89		%	1.68		%
Net loan charge-offs as a percentage of average total loans	1.68			2.09			2.14			2.08			1.26
Net credit-related charge-offs as a percentage of average total loans	1.68			2.10			2.14			2.08			1.26

(a) Primarily charge-offs of loans to real estate investors and developers.

(b) Primarily charge-offs of loans secured by owner-occupied real estate.

ANALYSIS OF THE ALLOWANCE FOR CREDIT LOSSES ON LENDING-RELATED COMMITMENTS (unaudited)

Comerica Incorporated and Subsidiaries

	2010		2009
(in millions)	1st Qtr		4th Qtr		3rd Qtr		2nd Qtr			1st Qtr
Balance at beginning of period	$	37	$	35	$	33	$	37		$	38
Less: Charge-offs on lending-related commitments (a)	—		1		—		—			—
Add: Provision for credit losses on lending-related commitments	7		3		2		(4		)	(1		)
Balance at end of period	$	44	$	37	$	35	$	33		$	37
Unfunded lending-related commitments sold	$	—	$	3	$	1	$	—		$	—

(a) Charge-offs result from the sale of unfunded lending-related commitments.

17

NONPERFORMING ASSETS (unaudited)

Comerica Incorporated and Subsidiaries

	2010			2009
(in millions)	1st Qtr			4th Qtr			3rd Qtr			2nd Qtr			1st Qtr
SUMMARY OF NONPERFORMING ASSETS AND PAST DUE LOANS
Nonaccrual loans:
Commercial	$	209		$	238		$	290		$	327		$	258
Real estate construction:
Commercial Real Estate business line (a)	516			507			542			472			426
Other business lines (b)	3			4			4			4			5
Total real estate construction	519			511			546			476			431
Commercial mortgage:
Commercial Real Estate business line (a)	105			127			137			134			131
Other business lines (b)	226			192			161			175			138
Total commercial mortgage	331			319			298			309			269
Residential mortgage	58			50			27			7			8
Consumer	13			12			8			7			8
Lease financing	11			13			18			—			2
International	4			22			7			4			6
Total nonaccrual loans	1,145			1,165			1,194			1,130			982
Reduced-rate loans	17			16			2			—			—
Total nonperforming loans	1,162			1,181			1,196			1,130			982
Foreclosed property	89			111			109			100			91
Total nonperforming assets	$	1,251		$	1,292		$	1,305		$	1,230		$	1,073
Nonperforming loans as a percentage of total loans	2.85		%	2.80		%	2.74		%	2.43		%	2.02		%
Nonperforming assets as a percentage of total loans and foreclosed property	3.06			3.06			2.99			2.64			2.20
Allowance for loan losses as a percentage of total nonperforming loans	85			83			80			78			83
Loans past due 90 days or more and still accruing	$	83		$	101		$	161		$	210		$	207
ANALYSIS OF NONACCRUAL LOANS
Nonaccrual loans at beginning of period	$	1,165		$	1,194		$	1,130		$	982		$	917
Loans transferred to nonaccrual (c)	245			266			361			419			241
Nonaccrual business loan gross charge-offs (d)	(174		)	(217		)	(226		)	(242		)	(153		)
Loans transferred to accrual status (c)	—			—			(4		)	—			(4		)
Nonaccrual business loans sold (e)	(44		)	(10		)	(41		)	(10		)	(3		)
Payments/Other (f)	(47		)	(68		)	(26		)	(19		)	(16		)
Nonaccrual loans at end of period	$	1,145		$	1,165		$	1,194		$	1,130		$	982

(a) Primarily loans to real estate investors and developers.
(b) Primarily loans secured by owner-occupied real estate.
(c) Based on an analysis of nonaccrual loans with book balances greater than $2 million.
(d) Analysis of gross loan charge-offs:
Nonaccrual business loans	$	174	$	217	$	226	$	242	$	153
Performing watch list loans	—		—		1		1		—
Consumer and residential mortgage loans	10		15		18		14		8
Total gross loan charge-offs	$	184	$	232	$	245	$	257	$	161
(e) Analysis of loans sold:
Nonaccrual business loans	$	44	$	10	$	41	$	10	$	3
Performing watch list loans	12		1		24		6		—
Total loans sold	$	56	$	11	$	65	$	16	$	3

(f)Includes net changes related to nonaccrual loans with balances less than $2 million, payments on nonaccrual loans with book balances greater than $2 million and transfers of nonaccrual loans to foreclosed property. Excludes business loan gross charge-offs and business nonaccrual loans sold.

18

ANALYSIS OF NET INTEREST INCOME (FTE) (unaudited)

Comerica Incorporated and Subsidiaries

	Three Months Ended
	March 31, 2010							December 31, 2009							March 31, 2009
	Average					Average		Average					Average		Average					Average
(dollar amounts in millions)	Balance			Interest		Rate		Balance			Interest		Rate		Balance			Interest		Rate
Commercial loans	$	21,015		$	205	3.96	%	$	21,971		$	212	3.84	%	$	27,180		$	228	3.39	%
Real estate construction loans	3,386			25		2.95		3,703			27		2.90		4,510			33		2.99
Commercial mortgage loans	10,387			107		4.18		10,393			110		4.19		10,431			109		4.22
Residential mortgage loans	1,632			22		5.41		1,664			21		5.01		1,846			26		5.66
Consumer loans	2,481			22		3.58		2,517			23		3.59		2,574			24		3.79
Lease financing	1,130			11		3.75		1,181			11		3.80		1,300			9		2.82
International loans	1,282			12		3.93		1,324			12		3.73		1,715			16		3.85
Business loan swap income	—			8		—		—			9		—		—			8		—
Total loans	41,313			412		4.04		42,753			425		3.95		49,556			453		3.70
Auction-rate securities available-for-sale	879			2		0.93		923			3		1.37		1,108			5		1.71
Other investment securities available-for-sale	6,503			60		3.72		7,664			51		2.67		9,018			105		4.82
Total investment securities available-for-sale	7,382			62		3.38		8,587			54		2.53		10,126			110		4.46
Federal funds sold and securities purchased under agreements to resell	—			—		—		1			—		0.29		57			—		0.32
Interest-bearing deposits with banks (a)	4,122			2		0.25		2,480			1		0.25		1,848			1		0.23
Other short-term investments	124			1		1.75		132			1		1.55		165			1		1.67
Total earning assets	52,941			477		3.65		53,953			481		3.55		61,752			565		3.71
Cash and due from banks	788							831							950
Allowance for loan losses	(1,058		)					(1,048		)					(832		)
Accrued income and other assets	4,848							4,660							4,867
Total assets	$	57,519						$	58,396						$	66,737
Money market and NOW deposits	$	15,055		12		0.32		$	14,113		14		0.39		$	12,334		19		0.63
Savings deposits	1,384			—		0.07		1,376			—		0.08		1,278			1		0.18
Customer certificates of deposit	6,173			15		1.02		6,823			25		1.42		8,856			58		2.67
Total interest-bearing core deposits	22,612			27		0.50		22,312			39		0.69		22,468			78		1.41
Other time deposits	877			8		3.53		1,493			12		3.22		6,280			46		3.01
Foreign office time deposits	458			—		0.21		550			—		0.22		670			1		0.42
Total interest-bearing deposits	23,947			35		0.60		24,355			51		0.83		29,418			125		1.73
Short-term borrowings	234			—		0.11		222			—		0.09		2,362			2		0.29
Medium- and long-term debt	10,775			26		0.95		11,140			32		1.12		14,924			52		1.40
Total interest-bearing sources	34,956			61		0.71		35,717			83		0.92		46,704			179		1.55
Noninterest-bearing deposits	14,624							14,430							11,364
Accrued expenses and other liabilities	1,075							1,225							1,514
Total shareholders’ equity	6,864							7,024							7,155
Total liabilities and shareholders’ equity	$	57,519						$	58,396						$	66,737
Net interest income/rate spread (FTE)				$	416	2.94					$	398	2.63					$	386	2.16
FTE adjustment				$	1						$	2						$	2
Impact of net noninterest-bearing sources of funds						0.24							0.31							0.37
Net interest margin (as a percentage of average earning assets) (FTE) (a)						3.18	%						2.94	%						2.53	%

(a)Excess liquidity, represented by average balances deposited with the Federal Reserve Bank, reduced the net interest margin by 24 basis points in the first quarter of 2010, and by 13 basis points and 7 basis points in the fourth and first quarters of 2009, respectively.  Excluding excess liquidity, the net interest margin would have been 3.42%, 3.07% and 2.60% in each respective period. See Reconciliation of Non-GAAP Financial Measures.

19

CONSOLIDATED STATISTICAL DATA (unaudited)

Comerica Incorporated and Subsidiaries

	March 31,			December 31,			September 30,			June 30,			March 31,
(in millions, except per share data)	2010			2009			2009			2009			2009
Commercial loans:
Floor plan	$	1,351		$	1,367		$	857		$	1,492		$	1,763
Other	19,405			20,323			21,689			23,430			24,668
Total commercial loans	20,756			21,690			22,546			24,922			26,431
Real estate construction loans:
Commercial Real Estate business line (a)	2,741			2,988			3,328			3,500			3,711
Other business lines (b)	461			473			542			652			668
Total real estate construction loans	3,202			3,461			3,870			4,152			4,379
Commercial mortgage loans:
Commercial Real Estate business line (a)	1,880			1,824			1,678			1,728			1,659
Other business lines (b)	8,478			8,633			8,702			8,672			8,855
Total commercial mortgage loans	10,358			10,457			10,380			10,400			10,514
Residential mortgage loans	1,631			1,651			1,679			1,759			1,836
Consumer loans:
Home equity	1,769			1,803			1,804			1,801			1,791
Other consumer	703			708			740			761			786
Total consumer loans	2,472			2,511			2,544			2,562			2,577
Lease financing	1,120			1,139			1,197			1,234			1,232
International loans	1,306			1,252			1,355			1,523			1,655
Total loans	$	40,845		$	42,161		$	43,571		$	46,552		$	48,624
Goodwill	$	150		$	150		$	150		$	150		$	150
Loan servicing rights	6			7			8			9			10
Tier 1 common capital ratio (c) (d)	9.58		%	8.18		%	8.04		%	7.66		%	7.32		%
Tier 1 risk-based capital ratio (d)	10.40			12.46			12.21			11.58			11.06
Total risk-based capital ratio (d)	14.93			16.93			16.79			15.97			15.36
Leverage ratio (d)	11.00			13.25			12.46			12.11			11.65
Tangible common equity ratio (c)	9.68			7.99			7.96			7.55			7.27
Book value per common share	$	32.15		$	32.27		$	32.36		$	32.78		$	33.40
Market value per share for the quarter:
High	39.36			32.30			31.83			26.47			21.20
Low	29.68			26.49			19.94			16.03			11.72
Close	38.04			29.57			29.67			21.15			18.31
Quarterly ratios:
Return on average common shareholders’ equity	(5.61		)%	(5.10		)%	(1.27		)%	(1.25		)%	(1.90		)%
Return on average assets	0.36			(0.19		)	0.12			0.11			0.06
Efficiency ratio	66.45			70.68			67.14			72.75			66.61
Number of banking centers	449			447			444			441			440
Number of employees - full time equivalent	9,215			9,330			9,384			9,497			9,696

(a) Primarily loans to real estate investors and developers.

(b) Primarily loans secured by owner-occupied real estate.

(c) See Reconciliation of Non-GAAP Financial Measures.

(d) March 31, 2010 ratios are estimated.

20

PARENT COMPANY ONLY BALANCE SHEETS (unaudited)

Comerica Incorporated

	March 31,			December 31,			March 31,
(in millions, except share data)	2010			2009			2009
ASSETS
Cash and due from subsidiary bank	$	14		$	5		$	15
Short-term investments with subsidiary bank	651			2,150			2,229
Other short-term investments	86			86			75
Investment in subsidiaries, principally banks	5,818			5,710			5,780
Premises and equipment	4			4			4
Other assets	206			186			216
Total assets	$	6,779		$	8,141		$	8,319
LIABILITIES AND SHAREHOLDERS’ EQUITY
Medium- and long-term debt	$	989		$	986		$	999
Other liabilities	122			126			137
Total liabilities	1,111			1,112			1,136
Fixed rate cumulative perpetual preferred stock, series F,no par value, $1,000 liquidation preference per share:
Authorized - 2,250,000 shares at 12/31/09 and 3/31/09
Issued — 2,250,000 shares at 12/31/09 and 3/31/09	—			2,151			2,134
Common stock - $5 par value:
Authorized - 325,000,000 shares
Issued - 203,878,110 shares at 3/31/10 and 178,735,252 shares at 12/31/09 and 3/31/09	1,019			894			894
Capital surplus	1,468			740			727
Accumulated other comprehensive loss	(303		)	(336		)	(238		)
Retained earnings	5,064			5,161			5,252
Less cost of common stock in treasury - 27,575,283 shares at 3/31/10, 27,555,623 shares at 12/31/09 and 27,580,899 shares at 3/31/09	(1,580		)	(1,581		)	(1,586		)
Total shareholders’ equity	5,668			7,029			7,183
Total liabilities and shareholders’ equity	$	6,779		$	8,141		$	8,319

CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY (unaudited)

Comerica Incorporated and Subsidiaries

										Accumulated
				Common Stock						Other									Total
	Preferred			Shares			Capital			Comprehensive			Retained			Treasury			Shareholders’
(in millions, except per share data)	Stock			Outstanding	Amount		Surplus			Loss			Earnings			Stock			Equity
BALANCE AT DECEMBER 31, 2008	$	2,129		150.5	$	894	$	722		$	(309	)	$	5,345		$	(1,629	)	$	7,152
Net income	—			—	—		—			—			9			—			9
Other comprehensive income, net of tax	—			—	—		—			71			—			—			71
Total comprehensive income																			80
Cash dividends declared on preferred stock	—			—	—		—			—			(57		)	—			(57		)
Cash dividends declared on common stock ($0.05 per share)	—			—	—		—			—			(7		)	—			(7		)
Accretion of discount on preferred stock	5			—	—		—			—			(5		)	—			—
Net issuance of common stock under employee stock plans	—			0.7	—		(12		)	—			(33		)	43			(2		)
Share-based compensation	—			—	—		11			—			—			—			11
Other	—			—	—		6			—			—			—			6
BALANCE AT MARCH 31, 2009	$	2,134		151.2	$	894	$	727		$	(238	)	$	5,252		$	(1,586	)	$	7,183
BALANCE AT DECEMBER 31, 2009	$	2,151		151.2	$	894	$	740		$	(336	)	$	5,161		$	(1,581	)	$	7,029
Net income	—			—	—		—			—			52			—			52
Other comprehensive income, net of tax	—			—	—		—			33			—			—			33
Total comprehensive income																			85
Cash dividends declared on preferred stock	—			—	—		—			—			(38		)	—			(38		)
Cash dividends declared on common stock ($0.05 per share)	—			—	—		—			—			(9		)	—			(9		)
Purchase of common stock	—			—	—		—			—			—			(2		)	(2		)
Issuance of common stock	—			25.1	125		724			—			—			—			849
Redemption of preferred stock	(2,250		)	—	—		—			—			—			—			(2,250		)
Redemption discount accretion on preferred stock	94			—	—		—			—			(94		)	—			—
Accretion of discount on preferred stock	5			—	—		—			—			(5		)	—			—
Net issuance of common stock under employee stock plans	—			—	—		—			—			(3		)	3			—
Share-based compensation	—			—	—		4			—			—			—			4
Other	—			—	—		—			—			—			—			—
BALANCE AT MARCH 31, 2010	$	—		176.3	$	1,019	$	1,468		$	(303	)	$	5,064		$	(1,580	)	$	5,668

21

BUSINESS SEGMENT FINANCIAL RESULTS (unaudited)

Comerica Incorporated and Subsidiaries

							Wealth &
(dollar amounts in millions)	Business			Retail			Institutional
Three Months Ended March 31, 2010	Bank			Bank			Management			Finance			Other			Total
Earnings summary:
Net interest income (expense) (FTE)	$	341		$	130		$	42		$	(105	)	$	8		$	416
Provision for loan losses	137			31			12			—			(5		)	175
Noninterest income	76			44			60			12			2			194
Noninterest expenses	162			154			73			2			13			404
Provision (benefit) for income taxes (FTE)	29			(4		)	6			(36		)	1			(4		)
Income from discontinued operations, net of tax	—			—			—			—			17			17
Net income (loss)	$	89		$	(7	)	$	11		$	(59	)	$	18		$	52
Net credit-related charge-offs	$	137		$	26		$	10		$	—		$	—		$	173
Selected average balances:
Assets	$	31,293		$	6,106		$	4,862		$	9,416		$	5,842		$	57,519
Loans	30,918			5,599			4,789			9			(2		)	41,313
Deposits	17,750			16,718			2,791			1,218			94			38,571
Liabilities	17,711			16,678			2,777			12,601			888			50,655
Attributed equity	3,159			589			357			919			1,840			6,864
Statistical data:
Return on average assets (a)	1.13		%	(0.17		)%	0.92		%	N/M			N/M			0.36		%
Return on average attributed equity	11.24			(4.86		)	12.50			N/M			N/M			(5.61		)
Net interest margin (b)	4.48			3.18			3.53			N/M			N/M			3.18
Efficiency ratio	38.72			88.44			73.18			N/M			N/M			66.45

							Wealth &
	Business			Retail			Institutional
Three Months Ended December 31, 2009	Bank			Bank			Management			Finance			Other			Total
Earnings summary:
Net interest income (expense) (FTE)	$	343		$	129		$	42		$	(125	)	$	9		$	398
Provision for loan losses	179			36			19			—			22			256
Noninterest income	77			48			60			26			3			214
Noninterest expenses	165			161			76			2			21			425
Provision (benefit) for income taxes (FTE)	11			(8		)	2			(39		)	(6		)	(40		)
Income from discontinued operations, net of tax	—			—			—			—			—			—
Net income (loss)	$	65		$	(12	)	$	5		$	(62	)	$	(25	)	$	(29	)
Net credit-related charge-offs	$	183		$	30		$	12		$	—		$	—		$	225
Selected average balances:
Assets	$	32,655		$	6,257		$	4,841		$	10,683		$	3,960		$	58,396
Loans	32,289			5,733			4,746			—			(15		)	42,753
Deposits	16,944			17,020			2,849			1,892			80			38,785
Liabilities	16,903			16,978			2,837			13,722			932			51,372
Attributed equity	3,376			606			373			899			1,770			7,024
Statistical data:
Return on average assets (a)	0.80		%	(0.27		)%	0.38		%	N/M			N/M			(0.19		)%
Return on average attributed equity	7.70			(7.76		)	4.91			N/M			N/M			(5.10		)
Net interest margin (b)	4.21			3.02			3.50			N/M			N/M			2.94
Efficiency ratio	39.22			90.98			75.98			N/M			N/M			70.68

							Wealth &
	Business			Retail			Institutional
Three Months Ended March 31, 2009	Bank			Bank			Management			Finance			Other			Total
Earnings summary:
Net interest income (expense) (FTE)	$	312		$	126		$	36		$	(99	)	$	11		$	386
Provision for loan losses	177			23			10			—			(7		)	203
Noninterest income	93			46			70			20			(6		)	223
Noninterest expenses	157			161			75			4			—			397
Provision (benefit) for income taxes (FTE)	15			(5		)	8			(33		)	16			1
Income from discontinued operations, net of tax	—			—			—			—			1			1
Net income (loss)	$	56		$	(7	)	$	13		$	(50	)	$	(3	)	$	9
Net credit-related charge-offs	$	123		$	26		$	8		$	—		$	—		$	157
Selected average balances:
Assets	$	39,505		$	6,875		$	4,870		$	12,703		$	2,784		$	66,737
Loans	38,527			6,284			4,750			(4		)	(1		)	49,556
Deposits	14,040			17,391			2,429			6,786			136			40,782
Liabilities	14,372			17,367			2,418			24,914			511			59,582
Attributed equity	3,345			658			340			1,177			1,635			7,155
Statistical data:
Return on average assets (a)	0.57		%	(0.16		)%	1.10		%	N/M			N/M			0.06		%
Return on average attributed equity	6.78			(4.48		)	15.80			N/M			N/M			(1.90		)
Net interest margin (b)	3.28			2.93			3.11			N/M			N/M			2.53
Efficiency ratio	38.55			94.01			74.09			N/M			N/M			66.61

(a) Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b) Net interest margin is calculated based on the greater of average earning assets or average deposits and purchased funds.

FTE - Fully Taxable Equivalent

N/M — Not Meaningful

22

MARKET SEGMENT FINANCIAL RESULTS (unaudited)

Comerica Incorporated and Subsidiaries

																			Finance
(dollar amounts in millions)													Other						& Other
Three Months Ended March 31, 2010	Midwest			Western			Texas			Florida			Markets			International			Businesses			Total
Earnings summary:
Net interest income (expense) (FTE)	$	205		$	161		$	79		$	10		$	40		$	18		$	(97	)	$	416
Provision for loan losses	81			59			17			3			23			(3		)	(5		)	175
Noninterest income	102			36			20			3			10			9			14			194
Noninterest expenses	186			105			60			9			21			8			15			404
Provision (benefit) for income taxes (FTE)	14			11			8			—			(10		)	8			(35		)	(4		)
Income from discontinued operations, net of tax	—			—			—			—			—			—			17			17
Net income (loss)	$	26		$	22		$	14		$	1		$	16		$	14		$	(41	)	$	52
Net credit-related charge-offs	$	55		$	64		$	25		$	10		$	14		$	5		$	—		$	173
Selected average balances:
Assets	$	15,573		$	13,175		$	6,892		$	1,576		$	3,417		$	1,628		$	15,258		$	57,519
Loans	15,332			12,980			6,704			1,576			3,126			1,588			7			41,313
Deposits	17,068			11,927			4,957			361			1,973			973			1,312			38,571
Liabilities	17,044			11,846			4,941			347			2,010			978			13,489			50,655
Attributed equity	1,446			1,315			670			164			352			158			2,759			6,864
Statistical data:
Return on average assets (a)	0.55		%	0.67		%	0.84		%	0.17		%	1.85		%	3.50		%	N/M			0.36		%
Return on average attributed equity	7.09			6.68			8.66			1.60			17.97			36.09			N/M			(5.61		)
Net interest margin (b)	4.86			5.04			4.79			2.54			5.23			4.64			N/M			3.18
Efficiency ratio	60.64			53.08			60.36			72.04			43.87			29.12			N/M			66.45

																			Finance
													Other						& Other
Three Months Ended December 31, 2009	Midwest			Western			Texas			Florida			Markets			International			Businesses			Total
Earnings summary:
Net interest income (expense) (FTE)	$	205		$	163		$	78		$	10		$	40		$	18		$	(116	)	$	398
Provision for loan losses	101			79			20			—			15			19			22			256
Noninterest income	106			33			23			3			11			9			29			214
Noninterest expenses	194			110			61			9			20			8			23			425
Provision (benefit) for income taxes (FTE)	4			—			7			1			(7		)	—			(45		)	(40		)
Income from discontinued operations, net of tax	—			—			—			—			—			—			—			—
Net income (loss)	$	12		$	7		$	13		$	3		$	23		$	—		$	(87	)	$	(29	)
Net credit-related charge-offs	$	97		$	85		$	13		$	4		$	13		$	13		$	—		$	225
Selected average balances:
Assets	$	16,090		$	13,484		$	7,118		$	1,608		$	3,765		$	1,688		$	14,643		$	58,396
Loans	15,811			13,289			6,934			1,613			3,458			1,663			(15		)	42,753
Deposits	17,200			11,899			4,737			333			1,705			939			1,972			38,785
Liabilities	17,185			11,817			4,723			318			1,747			928			14,654			51,372
Attributed equity	1,529			1,386			691			176			401			172			2,669			7,024
Statistical data:
Return on average assets (a)	0.26		%	0.21		%	0.75		%	0.63		%	2.41		%	0.06		%	N/M			(0.19		)%
Return on average attributed equity	3.17			2.00			7.73			5.72			22.60			0.58			N/M			(5.10		)
Net interest margin (b)	4.73			4.85			4.46			2.57			4.57			4.22			N/M			2.94
Efficiency ratio	62.55			56.08			60.22			69.94			40.93			28.74			N/M			70.68

																			Finance
													Other						& Other
Three Months Ended March 31, 2009	Midwest			Western			Texas			Florida			Markets			International			Businesses			Total
Earnings summary:
Net interest income (expense) (FTE)	$	194		$	146		$	70		$	11		$	39		$	14		$	(88	)	$	386
Provision for loan losses	83			88			9			15			15			—			(7		)	203
Noninterest income	127			36			21			3			14			8			14			223
Noninterest expenses	194			104			58			8			21			8			4			397
Provision (benefit) for income taxes (FTE)	15			(3		)	9			(3		)	(5		)	5			(17		)	1
Income from discontinued operations, net of tax	—			—			—			—			—			—			1			1
Net income (loss)	$	29		$	(7	)	$	15		$	(6	)	$	22		$	9		$	(53	)	$	9
Net credit-related charge-offs	$	54		$	76		$	8		$	12		$	6		$	1		$	—		$	157
Selected average balances:
Assets	$	19,139		$	15,443		$	8,069		$	1,869		$	4,553		$	2,177		$	15,487		$	66,737
Loans	18,267			15,253			7,847			1,878			4,246			2,070			(5		)	49,556
Deposits	16,697			10,640			4,198			253			1,359			713			6,922			40,782
Liabilities	17,012			10,571			4,212			245			1,415			702			25,425			59,582
Attributed equity	1,604			1,375			679			152			383			150			2,812			7,155
Statistical data:
Return on average assets (a)	0.62		%	(0.18		)%	0.72		%	(1.29		)%	1.93		%	1.69		%	N/M			0.06		%
Return on average attributed equity	7.45			(1.98		)	8.53			(15.87		)	22.97			24.55			N/M			(1.90		)
Net interest margin (b)	4.30			3.91			3.62			2.31			3.65			2.74			N/M			2.53
Efficiency ratio	60.06			57.17			64.43			61.06			43.82			33.86			N/M			66.61

(a) Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b) Net interest margin is calculated based on the greater of average earning assets or average deposits and purchased funds.

FTE - Fully Taxable Equivalent

N/M — Not Meaningful

23

RECONCILIATION OF NON-GAAP FINANCIAL MEASURES (unaudited)

Comerica Incorporated and Subsidiaries

	March 31,			December 31,			September 30,			June 30,			March 31,
(dollar amounts in millions)	2010			2009			2009			2009			2009
Tier 1 capital (a) (b)	$	6,311		$	7,704		$7,735			$	7,774		$	7,760
Less:
Fixed rate cumulative perpetual preferred stock	—			2,151			2,145			2,140			2,134
Trust preferred securities	495			495			495			495			495
Tier 1 common capital (b)	$	5,816		$	5,058		$	5,095		$	5,139		$	5,131
Risk-weighted assets (a) (b)	$	60,680		$	61,815		$	63,355		$	67,124		$	70,135
Tier 1 common capital ratio (b)	9.58		%	8.18		%	8.04		%	7.66		%	7.32		%
Total shareholders’ equity	$	5,668		$	7,029		$	7,035		$	7,093		$	7,183
Less:
Fixed rate cumulative perpetual preferred stock	—			2,151			2,145			2,140			2,134
Goodwill	150			150			150			150			150
Other intangible assets	7			8			8			10			11
Tangible common equity	$	5,511		$	4,720		$	4,732		$	4,793		$	4,888
Total assets	$	57,106		$	59,249		$	59,590		$	63,630		$	67,370
Less:
Goodwill	150			150			150			150			150
Other intangible assets	7			8			8			10			11
Tangible assets	$	56,949		$	59,091		$	59,432		$	63,470		$	67,209
Tangible common equity ratio	9.68		%	7.99		%	7.96		%	7.55		%	7.27		%
	2010			2009
	1st Qtr			4th Qtr			3rd Qtr			2nd Qtr			1st Qtr
Net interest income (FTE)	$	416		$	398		$	387		$	404		$	386
Less:
Interest earned on excess liquidity (c)	3			2			2			1			1
Net interest income (FTE), excluding excess liquidity	$	413		$	396		$	385		$	403		$	385
Average earning assets	$	52,941		$	53,953		$	57,513		$	59,522		$	61,752
Less:
Average net unrealized gains on investment securities available-for-sale	62			107			102			239			212
Average earning assets for net interest margin (FTE)	52,879			53,846			57,411			59,283			61,540
Less:
Excess liquidity (c)	4,092			2,453			3,492			1,833			1,812
Average earning assets for net interest margin (FTE), excluding excess liquidity	$	48,787		$	51,393		$	53,919		$	57,450		$	59,728
Net interest margin (FTE)	3.18		%	2.94		%	2.68		%	2.73		%	2.53		%
Net interest margin (FTE), excluding excess liquidity	3.42			3.07			2.84			2.81			2.60
Impact of excess liquidity on net interest margin (FTE)	(0.24		)	(0.13		)	(0.16		)	(0.08		)	(0.07		)

(a) Tier 1 capital and risk-weighted assets as defined by regulation.

(b) March 31, 2010 Tier 1 capital and risk-weighted assets are estimated.

(c) Excess liquidity represented by interest earned on and average balances deposited with the Federal Reserve Bank.

24

EX-99.2

Exhibit 99.2

First Quarter 2010 Financial Review April 21, 2010 Comerica Incorporated

Safe Harbor Statement Any statements in this presentation that are not historical facts are forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. Words such as "anticipates," "believes," "feels," "expects," "estimates," "seeks," "strives," "plans," "intends," "outlook," "forecast," "position," "target," "mission," "assume," "achievable," "potential," "strategy," "goal," "aspiration," "outcome," "continue," "remain," "maintain," "trend," "objective" and variations of such words and similar expressions, or future or conditional verbs such as "will," "would," "should," "could," "might," "can," "may" or similar expressions, as they relate to Comerica or its management, are intended to identify forward-looking statements. These forward-looking statements are predicated on the beliefs and assumptions of Comerica’s management 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, Comerica’s actual results could differ materially from those discussed. Factors that could cause or contribute to such differences are further economic downturns, changes in the pace of an economic recovery and related changes in employment levels, changes in real estate values, fuel prices, energy costs or other events that could affect customer income levels or general economic conditions, the effects of recently enacted legislation, actions taken by or proposed by the U.S. Department of Treasury, the Board of Governors of the Federal Reserve System, the Texas Department of Banking and the Federal Deposit Insurance Corporation, legislation enacted in the future, and the impact and expiration of such legislation and regulatory actions, the effects of war and other armed conflicts or acts of terrorism, the effects of natural disasters including, but not limited to, hurricanes, tornadoes, earthquakes, fires, droughts and floods, the disruption of private or public utilities, the implementation of Comerica’s strategies and business models, management’s ability to maintain and expand customer relationships, changes in customer borrowing, repayment, investment and deposit practices, management’s ability to retain key officers and employees, changes in the accounting treatment of any particular item, the impact of regulatory examinations, declines or other changes in the businesses or industries in which Comerica has a concentration of loans, including, but not limited to, the automotive production industry and the real estate business lines, the anticipated performance of any new banking centers, the entry of new competitors in Comerica’s markets, changes in the level of fee income, changes in applicable laws and regulations, including those concerning taxes, banking, securities and insurance, changes in trade, monetary and fiscal policies, including the interest rate policies of the Board of Governors of the Federal Reserve System, fluctuations in inflation or interest rates, changes in general economic, political or industry conditions and related credit and market conditions, the interdependence of financial service companies and adverse conditions in the stock market. Comerica cautions that the foregoing list of factors is not exclusive. For discussion of factors that may cause actual results to differ from expectations, please refer to our filings with the Securities and Exchange Commission. In particular, please refer to “Item 1A. Risk Factors” beginning on page 11 of Comerica’s Annual Report on Form 10-K for the year ended December 31, 2009. 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 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.

Financial Results $ in millions, except per share data 1Included noncash charges of $99 million related to preferred stock issued to the U.S. Treasury under the Capital Purchase Program, which was fully redeemed during the quarter 2 Estimated 3 See Supplemental Financial Data slide for reconciliation of non-GAAP financial measures $8 $(29) $35 Income (loss) from continuing operations, net of tax 1 - 17 Income from discontinued operations, net of tax 9.68% 10.40%2 404 194 175 3.18% 415 (0.46) (71) 1231 52 1Q10 11.06% 12.46% Tier 1 capital ratio (24) (62) Net loss attributable to common shares 33 33 Preferred stock dividends to U.S. Treasury 397 425 Noninterest expenses 7.27% 7.99% Tangible common equity ratio3 223 214 Noninterest income 203 256 Provision for loan losses 2.53% 2.94% Net interest margin 384 396 Net interest income (0.16) (0.42) Diluted loss per common share 9 (29) Net income (loss) 1Q09 4Q09

First Quarter 2010 Highlights Analysis of 1Q10 compared to 4Q09 1Based on an analysis of nonaccrual loans with book balances greater than $2 million 2 See Supplemental Financial Data slides for reconciliation of non-GAAP financial measures Credit quality improved Net credit related charge-offs declined by $52 million to $173 million Provision for credit losses declined $77 million to $182 million Nonperforming assets declined $41 million Inflow to nonaccrual1 slowed by $21 million, to $245 million Net interest income grew 5% as the net interest margin increased 24 basis points to 3.18% Excluding impact of excess liquidity, net interest margin would have been 3.42%2 Higher-cost funding matured and loan spreads increased Expenses well controlled Noninterest expenses decreased 5% 5% reduction in workforce from a year ago Capital ratios remain strong after fully redeeming $2.25 billion of preferred stock issued to the U.S. Treasury Tangible common equity ratio2 of 9.68%

$880MM common stock offering completed on March 12 Redeemed $2.25 billion of preferred stock issued to the U.S. Treasury under the Capital Purchase Program on March 17. 1Q10 negative impact of $123 million or $0.79 per share: Quarterly cash dividend of $24 million or $0.15 per share Quarterly non-cash accretion of the discount of $5 million or $0.03 per share One-time non-cash redemption charge (accelerated accretion of the remaining discount) of $94 million or $0.61 per share Elected not to repurchase the warrant issued in conjunction with the preferred stock (11.5 million shares of common stock at an exercise price of $29.40 per share) in order to preserve capital in support of future growth Redemption of Preferred Stock

Loan Decline Slowing Average Loan Outstandings Average Change in Loan Outstandings (217) $1.4B decline in average loans in 1Q10 compared to 4Q09 1Q10 Comerica new and renewed lending activity: $6.0B Middle market & small businesses working capital needs should increase with GDP TX & CA expected to benefit from population growth & diverse economies Auto Dealer floorplan financing expected to increase as sales pickup Average balances in $ millions $30,000 $35,000 $40,000 $45,000 3Q09 4Q09 Jan '10 Feb '10 Mar '10 (2,866) (2,029) (846) (357) ($4,000) ($3,000) ($2,000) ($1,000) $0

Diverse Loan Portfolio 1 Specialty Businesses includes: Entertainment, Energy, Financial Services Division, Leasing, Technology and Life Sciences (TLS), and Mortgage Banker Finance Geography based on office of origination; Midwest: MI, OH, IL; Western: CA, AZ, NV, CO, WA; Other Markets include markets not separately identified above in addition to businesses with a national perspective Average 1Q10: $41.3 billion Other Markets $3.1B 8% Int'l $1.6B 4% Florida $1.6B 4% Midwest $15.3B 37% Western $13.0B 31% Texas $6.7B 16% Global Corp Banking $4.9B 12% Commercial Real Estate $5.4B 13% Middle Market $12.7B 31% Nat'l Dealer Services $3.2B 8% Specialty Businesses 1 $4.7B 11% Personal Banking $1.9B 5% Small Business Banking $3.7B 9% Private Banking $4.8B 11%

Growing Core Deposits Total avg. core deposits1 of $37.2B, a $494MM increase Money market and NOW deposits increased $942MM Noninterest-bearing deposits grew $194MM Higher-cost customer CDs declined $650MM Total avg. core deposits: Increased in Texas and Florida markets Relatively stable in Midwest and Western markets Increased in most commercial lines of business Average Noninterest-Bearing Deposits $ in billions; 1Q10 vs 4Q09 1Core deposits exclude Institutional CDs, Retail Brokered CDs and foreign office time deposits $3 $6 $9 $12 $15 4Q08 1Q09 2Q09 3Q09 4Q09 1Q10

Net Interest Margin Expansion Net interest margin of 3.18% which reflected: + Loan spread improvement + Less costly blend of core deposits + Maturities of higher-cost wholesale funding Excess liquidity position1: 1Q10 Average $4.1B 3/31/10 period end $3.8B Resulted from continued deposit growth and weak loan demand Negative impact on 1Q10 margin was approximately 24 basis points 1Excess liquidity represented by average deposits held at the Federal Reserve Bank. See Supplemental Financial Data slide for reconciliation of non-GAAP financial measure. 0.13% 0.24% 3.18% 2.94% 2.68% 2.73% 2.53% 0.16% 0.08% 0.07% 2.84% 3.07% 2.60% 2.81% 3.42% 2.25% 2.50% 2.75% 3.00% 3.25% 3.50% 1Q09 2Q09 3Q09 4Q09 1Q10 Reported Net Interest Margin Impact of Excess Liquidity

A Leaner, More Efficient Company Workforce Reductions 11Q10 vs 4Q09 1Q10 noninterest expense decreased 5%1 : Salary and employee benefits expense reduced 6% Workforce reductions in 2009 benefit 2010 Other Real Estate expense decreased $10MM Continued to tightly control discretionary expenses 6,000 8,000 10,000 12,000 2001 2002 2003 2004 2005 2006 2007 2008 2009 1Q10 Headcount (period end) 200 250 300 350 400 450 Banking Centers (period end) Full-time Equivalent Employees Banking Centers

Credit Quality Improved 85% 2.42% $182 $1,031 $173 1.68% 1Q10 $308 $913 $313 $988 $259 $1,022 Provision for Credit Losses Allowance for Credit Losses 1.89% 2.19% 2.34% Allowance for loan losses to total loans 78% 80% 83% Allowance for loan losses to nonperforming loans $225 2.10% 4Q09 $239 2.14% 3Q09 $248 2.08% Net credit-related charge-offs to average total loans 2Q09 Net credit-related charge-offs declined $52 million; the third consecutive quarter of decline Reserve build continued, but at a slower pace with provision for credit losses exceeding net credit-related charge-offs by $9 million Allowance for loan losses to nonperforming loans increased $ in millions

Credit Quality Improved $100 $109 $111 $89 Foreclosed property $7,502 $83 $245 $1,251 3.06% 1Q10 $7,386 $8,250 $7,730 Total Watch list loans2 $419 $361 $266 Nonperforming assets inflow1 $101 $1,292 3.06% 4Q09 $161 $1,305 2.99% 3Q09 $210 Loans past due 90 days or more and still accruing $1,230 2.64% Nonperforming assets to total loans and foreclosed property 2Q09 Nonperforming assets declined by $41 million Inflow to nonaccrual slowed by $21 million; third consecutive quarter of declining inflow Watch list loans1 decreased $228 million, second consecutive quarter of decline Foreclosed property declined $22 million $ in millions 1Based on an analysis of nonaccrual loans with book balances greater than $2 million 2Watch list: generally consistent with regulatory defined special mention, substandard and doubtful loans

Net Loan Charge-offs Declined By Market By Line of Business $ in millions Geography based on office of origination; Midwest: MI, OH, IL; Western: CA, AZ, NV, CO, WA; Other Markets include markets not separately identified above in addition to businesses with a national perspective 239 224 173 248 $0 $50 $100 $150 $200 $250 $300 2Q09 3Q09 4Q09 1Q10 CRE Line of Business Middle Market Small Business WIM Specialty Businesses Personal Banking Global Corp Banking 173 224 239 248 $0 $50 $100 $150 $200 $250 $300 2Q09 3Q09 4Q09 1Q10 Midwest Western Texas Florida Other/Intl

Nonaccrual Loans March 31, 2010: $1,145 million By Line of Business Period-end balances in $ millions (MM) 1 Reflects office of origination Nonaccrual loans1: Western 44% Midwest 33% Florida 9% Texas 8% Other 6% Average carrying value of 56% (44% write-down) Included in nonperforming assets: $17MM in Reduced Rate loans $23MM in Troubled Debt Restructurings (TDRs) Foreclosed Property of $89MM Accruing TDRs total $8MM No nonaccrual loans Held-For-Sale Sold $44MM in nonperforming loans at prices approximating carrying value plus reserves 1,130 1,194 1,165 1,145 0 300 600 900 1,200 2Q09 3Q09 4Q09 1Q10 CRE Line of Business Small Business Banking Global Corp Banking Middle Market Private Banking Personal Banking Other Business Lines

Commercial Real Estate Line of Business March 31, 2010 Loan Outstandings: $4.6 billion1 By Project Type By Location of Property Period-end balances in $billions; additional Commercial Real Estate information can be found in the appendix 1 Excludes $0.5 B in Commercial Real Estate line of business loans not secured by real estate Multi-use $0.5B 10% Office $0.4B 10% Comml/Other $0.3B 7% Multi-family $1.2B 25% Retail $1.0B 22% Single Family $0.5B 11% Land Development $0.3B 6% Land Carry $0.4B 9% Other Markets $0.6B 14% Florida $0.5B 11% Western $1.7B 37% Michigan $0.6B 13% Texas $1.2B 25%

Commercial Real Estate Line of Business Net Charge Offs By Location of Property By Project Type $millions RE: Real Estate Commercial: Multi-Family, Retail, Office, Warehouse, Multi-use and Commercial Residential real estate charge-offs were stable Multi-use and multi-family charge-offs increased Western & Midwest charge-offs declined Texas charge-offs increased: primarily 2 projects Nonaccrual and watch list loans declined Expect variability in charge-offs with a downward trend $108 $91 $62 $86 $0 $20 $40 $60 $80 $100 $120 2Q09 3Q09 4Q09 1Q10 Residential Commercial Not Secured by RE $108 $91 $62 $86 $0 $20 $40 $60 $80 $100 $120 2Q09 3Q09 4Q09 1Q10 Western Midwest Florida Texas Other Not Secured by RE

Residential Real Estate Development Period-end balances in $millions Reduced Residential Real Estate Development exposure by $1.3B since 6/08 to $964MM at 3/10 Geographic breakdown: Western 44% Florida 15% Texas 17% Michigan 12% Other 12% 58% Decrease Reduced Western Market Local Residential Real Estate Developer Portfolio to $191MM at 3/31/10 from $932MM at 12/31/07 $0 $500 $1,000 $1,500 $2,000 $2,500 6/30/08 9/30/08 12/31/08 3/30/09 6/30/09 9/30/09 12/31/09 3/31/10 Single Family Residential - Land Carry/Development

Strong Capital Ratios Source: SNL Financial; 4Q09 Tangible Common Equity Ratio excludes PNC as that figure was not reported Peer Group: BBT, FITB, HBAN, KEY, MI, MTB, PNC, RF, STI, USB, ZION See Supplemental Financial Data for reconcilements of Comerica’s non-GAAP financial measures Tier I Common Tangible Common Equity Ratio Peer Median Comerica 7.3% 7.7% 8.0% 8.2% 9.6% 7.0% 7.0% 6.9% 5.7% 0% 2% 4% 6% 8% 10% 12% 1Q09 2Q09 3Q09 4Q09 1Q10 7.3% 7.6% 8.0% 8.0% 9.7% 6.1% 6.3% 6.0% 5.1% 0% 2% 4% 6% 8% 10% 12% 1Q09 2Q09 3Q09 4Q09 1Q10

2010 Full-Year Outlook1 Low single-digit loan growth, 3/31/10 compared to 12/31/10 Loan demand lags economic recovery Investment securities portfolio to remain at March 31, 2010 level Net interest margin between 3.25% and 3.35% Based on no increase in the Federal Funds rate Continued improvement from loan pricing, lower funding costs and a lower level of excess liquidity Net credit-related charge-offs between $675MM and $725MM Provision for credit losses to be consistent with net charge-offs Noninterest income flat to low single-digit decline2, excluding $243MM of 2009 net securities gains Noninterest expenses, low single-digit decrease2 Workforce reductions in 2009 will benefit 2010 Expect reduced pension, FDIC and ORE expenses Income tax expense to approximate 35% of pre-tax income less approximately $60 million in annual tax benefits 1This outlook is provided as of April 21, 2010. 2Full-year outlook: 2010 compared to 2009 Expectations based on a modestly improving economic environment

Appendix

Business and Market Segment Contributions to Net Income ($29) (25) (62) 5 (12) $65 4Q09 $9 $52 TOTAL (3) 18 Other1 (50) (59) Finance 13 11 Wealth & Institutional Management (7) (7) Retail Bank $56 $89 Business Bank 1Q09 1Q10 $ in millions 1Includes discontinued operations and items not directly associated with the three major business segments or the Finance Division 2Includes discontinued operations and items not directly associated with the geographic markets ($29) (87) -- 23 3 13 7 $12 4Q09 22 16 Other Markets (6) 1 Florida (7) 22 Western $9 $52 TOTAL (53) (41) Finance and Other2 9 14 International 15 14 Texas $29 $26 Midwest 1Q09 1Q10

Investment Securities Portfolio Consists primarily of AAA mortgage-backed Freddie Mac and Fannie Mae government agency securities Net unrealized pre-tax gain $84MM as of 3/31/10 Average life of 4.0 years Repurchased customers’ Auction Rate Securities in 4Q08 Cumulative redemptions of $406MM (1Q10 $47MM) Cumulative gains on redemptions of $21MM (1Q10 $2MM) $ in millions (MM) Expect Investment Securities to remain $6.5B $3,500 $4,500 $5,500 $6,500 $7,500 $8,500 $9,500 $10,500 1Q09 2Q09 3Q09 4Q09 1Q10 Average Auction Rate Securities Average Investment Securities Available-for-Sale

Loan Growth Post-Recession Source: Federal Reserve H.8 as of 4/7/10 Comerica’s C&I loan outstandings have begun to decline at a slower pace than most other banks. C&I Loans -25% -20% -15% -10% -5% 0% 5% 10% 15% 20% 25% 7/1/2007 11/1/2007 3/1/2008 7/1/2008 11/1/2008 3/1/2009 7/1/2009 11/1/2009 3/1/2010 52-Wk. % Change in 4-Wk. Moving Average Comerica All Banks Large Banks

Decline in Commercial Real Estate Loans Source: Federal Reserve H.8 as of 4/7/10 Comerica has proactively reduced exposure in Commercial Real Estate at a faster pace than most other banks. Commercial Real Estate Loans -25% -20% -15% -10% -5% 0% 5% 10% 15% 7/1/2007 11/1/2007 3/1/2008 7/1/2008 11/1/2008 3/1/2009 7/1/2009 11/1/2009 3/1/2010 52-Wk. % Change in 4-Wk. Moving Average Comerica All Banks Large Banks

Loans By Geographic Market 3.5 3.1 Other Markets 1.6 1.6 Florida 1.7 1.6 International $42.8 $41.3 TOTAL 6.9 6.7 Texas 13.3 13.0 Western $15.8 $15.3 Midwest 4Q09 1Q10 Average loans in $billions; Geography based on office of origination; Midwest: MI, OH, IL; Western: CA, AZ, NV, CO, WA; Other Markets include markets not separately identified above in addition to businesses with a national perspective

Loans by Line of Business $41.3 $4.8 4.8 $5.6 1.9 3.7 $30.9 4.7 3.2 4.9 5.4 $12.7 1Q10 $42.8 TOTAL $4.8 SUBTOTAL – WEALTH & INSTITUTIONAL MANAGEMENT 4.8 Private Banking $5.7 SUBTOTAL – RETAIL BANK 2.0 Personal Banking 3.7 Small Business Banking $32.3 SUBTOTAL – BUSINESS BANK 5.1 Specialty Businesses1 3.1 National Dealer Services 5.2 Global Corporate Banking 5.7 Commercial Real Estate $13.2 Middle Market 4Q09 Average loans in $billions; 1 Specialty Businesses includes: Financial Services Division, Entertainment, Energy, Leasing, Mortgage Banker Finance, and TLS

First Quarter 2010 Average Loans Detail $3.1 $0.0 0.0 $0.1 0.1 0.0 $3.0 0.7 0.2 0.5 0.6 $1.0 Other Markets $1.6 $0.7 0.7 $0.0 0.0 0.0 $0.9 0.0 0.2 0.1 0.4 $0.2 Florida $41.3 $1.6 $6.7 $13.0 $15.3 TOTAL $4.8 $0.0 $0.5 $1.7 $1.9 SUBTOTAL – WEALTH & INSTITUTIONAL MANAGEMENT 4.8 0.0 0.5 1.7 1.9 Private Banking $5.6 $0.0 $1.1 $1.0 $3.4 SUBTOTAL – RETAIL BANK 1.9 0.0 0.2 0.1 1.5 Personal Banking 3.7 0.0 0.9 0.9 1.9 Small Business Banking $30.9 $1.6 $5.1 $10.3 $10.0 SUBTOTAL – BUSINESS BANK 4.7 0.0 1.6 1.5 0.9 Specialty Businesses1 3.2 0.0 0.2 2.0 0.6 National Dealer Services 4.9 1.6 0.3 0.9 1.5 Global Corporate Banking 5.4 0.0 1.5 1.9 1.0 Commercial Real Estate $12.7 $0.0 $1.5 $4.0 $6.0 Middle Market TOTAL Int’l Texas Western Midwest $ in billions; geography based on office of origination. 1 Specialty Businesses includes: Financial Services Division, Entertainment, Energy, Leasing and TLS

Shared National Credit Relationships Outstandings declined $3.5B from 12/31/08 Approx. 975 borrowers Industry diversification mirrors total loan book Majority of relationships include ancillary business Comerica is agent for approximately 16% Adhere to same credit underwriting standards as rest of loan book Credit challenges focused primarily on residential real estate development March 31, 2010: $8.3 billion Shared National Credit (SNC): Facilities greater than $20 million shared by three or more federally supervised financial institutions which are reviewed by regulatory authorities at the agent bank level. Period-end outstandings as of March 31, 2010 Global Corp Banking $2.9B 35% Nat'l Dealer Services $0.3B 3% Energy $1.1B 14% Other $0.5B 6% Middle Market $2.0B 24% Commercial Real Estate $1.5B 18%

Automotive Manufacturer Portfolio $0.9 0.2 $0.7 12/09 $1.0 $1.5 $1.8 $2.2 $2.7 Total Other Automotive $0.8 $1.2 $1.4 $1.7 $2.0 Domestic Ownership 0.2 0.3 0.4 0.5 0.7 Foreign Ownership 12/05 12/06 12/07 12/08 2/10 Outstandings1 1Period-end in $billions 2$millions 3Period-end in $millions Portfolio includes OEM (Original Equipment Manufacturer), Tier One and Tier Two suppliers with greater than 50% revenue associated with auto manufacturing Fourth Quarter Commentary: Auto outstandings have declined 63% since 12/05 Expect outstandings to increase moderately as auto sales rise No direct exposure to GM or Chrysler down 63% $18 $6.4 YTD10 $28 $55.2 FY09 $5.5 $(2.2) Net Charge-offs/ (recovery)2 $16 $16 Nonaccrual Loans3 FY07 FY08

Diversified National Dealer Services Geographic Dispersion Western 61% Midwest 18% Florida 8% Texas 7% Other 6% 1Q10 Average Loans Outstanding: $3.2 billion Franchise Distribution1 1 Franchise distribution based on March 31, 2010 period-end outstandings 2 “Other” includes obligations where a primary franchise is indeterminable (rental car and leasing companies, heavy truck, recreational vehicles, and non-floor plan loans) Facts Top tier strategy Majority are Mega franchises (five or more dealers in group) Very small exposure to dealers that are being closed Excellent credit quality Average loan outstandings down $815 million or 20% from 1Q09 Detroit 3 nameplates down from 41% at 12/05 to 20% at 3/10 Toyota/ Lexus 24% Ford 10% GM 6% Chrysler 4% Mercedes 5% Nissan/ Infinity 5% Other 2 12% Other European 9% Other Asian 7% Honda/ Acura 18%

Net Loan Charge-offs by Line of Business $248 $239 $224 $173 TOTAL $312 $311 $256 $175 Provision for loan loss 8 10 12 10 WIM 33 18 18 9 Specialty Businesses1 2 6 20 39 $86 1Q10 26 8 22 76 $62 4Q09 52 64 Middle Market 17 6 23 $108 2Q09 23 8 25 $91 3Q09 Small Business Banking CRE Global Corporate Banking Personal Banking Average loans in $billions; 1 Specialty Businesses includes: Financial Services Division, Entertainment, Energy, Leasing, Mortgage Banker Finance, and TLS

Net Loan Charge-offs by Market $ in millions Geography based on office of origination; Midwest: MI, OH, IL; Western: CA, AZ, NV, CO, WA; Other Markets include markets not separately identified above in addition to businesses with a national perspective $175 $173 19 10 25 64 $55 1Q10 $256 $224 25 4 13 85 $97 4Q09 70 95 Western $312 $248 45 23 11 $99 2Q09 $311 $239 11 9 22 $102 3Q09 Texas Midwest TOTAL Other Markets/ International Provision for loan losses Florida

Nonaccrual Loans 3 97 Over $25MM 783 $1,145 Total 24 373 $10–$25MM 26 183 $5–$10MM 730 $492 Under $5MM # of Relationships Outstanding Period-end balances in $ millions (MM) as March 31, 2010 Proactively review nonaccrual loans every quarter Charge-offs and reserves taken to reflect current market conditions Granularity of nonaccrual loans: Carrying Value of Nonaccrual Loans as % of Contractual Value 72% 68% 66% 64% 61% 59% 56% 56% 25% 40% 55% 70% 2Q08 3Q08 4Q08 1Q09 2Q09 3Q09 4Q09 1Q10

Commercial Real Estate Loan Portfolio 1Q10: $13.8 billion 1Q10 averages in $billions 1 Included in Commercial Real Estate line of business Commercial Real Estate line of business: Nonaccrual loans of $631MM, a $16MM reduction from 4Q09 Loans over $2mm transferred to nonaccrual totaled $129MM ($64MM in 4Q09, $211MM in 3Q09) Net loan charge-offs of $86MM, expected to exhibit variability with a downward trend Primarily Owner- Occupied Commercial Mortgages $9.0B 65% Real Estate Construction 1 $2.9B 21% Commercial Mortgages 1 $1.9B 14%

Real Estate Construction Loans 65 - - 41 23 1 Commercial 226 33 14 62 5 112 Office 217 11 24 27 33 122 Multi-use 728 121 136 272 - 200 Multi-family Other CRE: 274 26 12 87 27 122 Land Development 700 80 96 117 57 350 Total Residential 729 40 48 346 123 172 Retail 47 - - 14 - 33 Other $2,741 $288 $318 $882 $256 $997 TOTAL Residential: 3 $54 Other Markets 29 - 3 15 8 Land Development $426 $84 $30 $30 $228 Single Family TOTAL Florida Texas Michigan Western March 31, 2010 period-end $ in millions Commercial Real Estate Line of Business by Location of Property

Commercial Mortgage Loans 236 76 - 16 - 144 Multi-use 298 59 24 2 57 156 Retail 221 11 12 12 56 130 Land Carry Other CRE: 264 35 47 45 64 73 Total Residential $56 $16 $7 $16 $3 $14 Single Family Residential: 140 39 - 12 27 62 Commercial 217 7 11 48 57 94 Office 415 65 98 126 71 55 Multi-family 89 55 - 1 9 24 Other $347 19 Other Markets $1,880 $192 $262 $341 $738 TOTAL 208 40 29 61 59 Land Carry TOTAL Florida Texas Michigan Western March 31, 2010 period-end $ in millions Commercial Real Estate Line of Business by Location of Property

Consumer Loan Portfolio 10% of total outstandings No sub-prime mortgage programs Self-originated & relationship oriented Net loan charge-offs of $10MM 1Q10: $4.1 billion 1Q10 averages in $billions 1 Residential mortgages we hold on our balance sheet are primarily associated with our Private Banking customers. The residential mortgages we originate through our banking centers are typically sold to a third party. 2 The “other” category includes automobile, personal watercraft, student and recreational vehicle loans. Consumer loans- Other 2 $0.7B 16% Consumer Loans-Home Equity $1.8B 44% Residential Mortgages 1 $1.6B 40%

Home Equity Portfolio 84% home equity lines and 16% home equity loans1 Avg. FICO score of 752 at origination1 86% have CLTV < 80%1 at origination Average loan vintage is 4.66 years1 Geographic Breakdown 1Q10 averages in $billions Geography based on office of origination 1Data on loans booked through our Consumer Loan Center which encompasses about 86% of our Home Equity Lines and Loans 1Q10: $1.8 billion Other Markets 0% Florida 2% Western 26% Texas 9% Midwest 63%

Core Deposits By Geographic Market $37.1 1.0 1.9 0.4 5.0 11.9 $16.9 1Q10 1.4 1.7 Other Markets 0.2 0.3 Florida 0.6 0.9 International $33.7 $36.6 TOTAL 4.2 4.8 Texas 10.6 11.9 Western $16.7 $17.0 Midwest 1Q09 4Q09 Average deposits in $ billions; Geography based on office of origination; Western includes: CA, AZ, NV, CO, WA Excludes Foreign Office Time Deposits (1Q10 $0.2B; 4Q09 $0.2B; 1Q09 $0.2B) and Finance/Other with Inst. & Retail Brokered CDs of $0.9B in 1Q10, $1.5B in 4Q09, and $6.3B in 1Q09

Line of Business Deposits $38.6 1.3 $2.8 2.8 $16.7 12.8 3.9 $17.8 5.5 0.1 6.4 1.1 $4.7 1Q10 6.9 2.0 Finance/Other2 40.8 $38.8 TOTAL $2.4 $2.8 SUBTOTAL – WEALTH & INSTITUTIONAL MANAGEMENT 2.4 2.8 Private Banking $17.4 $17.0 SUBTOTAL – RETAIL BANK 13.7 13.0 Personal Banking 3.7 4.0 Small Business Banking $14.1 $17.0 SUBTOTAL – BUSINESS BANK 4.9 5.4 Specialty Businesses1 0.1 0.2 National Dealer Services 4.4 5.8 Global Corporate Banking 0.6 0.8 Commercial Real Estate $4.1 $4.8 Middle Market 1Q09 4Q09 Average deposits in $billions 1 Specialty Businesses includes: Entertainment, Energy, Financial Services Division, Leasing. Mortgage Banker and TLS 2 Finance/Other includes Inst. and Retail Brokered CD’s: 1Q10 - $0.9B; 4Q09 - $1.5B; 1Q09 - $6.3B

First Quarter 2010 Average Deposits Detail $1.9 -- $0.0 0.0 $0.0 0.1 -- $1.8 0.8 0.0 0.8 0.1 $0.1 Other Markets $1.0 -- $-- -- $-- -- -- $1.0 -- -- 1.0 -- $-- Int’l 1.3 -- -- -- 1.3 Finance/Other2 $38.6 $0.4 $5.0 $11.9 $18.4 TOTAL $2.8 $0.2 $0.3 $1.6 $0.7 SUBTOTAL – WEALTH & INSTITUTIONAL MANAGEMENT 2.8 0.2 0.3 1.6 0.7 Private Banking $16.7 $-- $2.7 $2.0 $11.9 SUBTOTAL – RETAIL BANK 12.8 -- 1.6 1.0 10.1 Personal Banking 3.9 -- 1.1 1.0 1.8 Small Business Banking $17.8 $0.2 $2.0 $8.3 $4.5 SUBTOTAL – BUSINESS BANK 5.5 0.1 0.5 4.0 0.1 Specialty Businesses1 0.1 0.0 0.0 0.1 0.0 National Dealer Services 6.4 0.1 0.9 0.4 3.2 Global Corporate Banking 1.1 0.0 0.1 0.7 0.2 Commercial Real Estate $4.7 $0.0 $0.5 $3.1 $1.0 Middle Market TOTAL Florida Texas Western Midwest $ in billions 1 Specialty Businesses includes: Entertainment, Energy, Financial Services Division, Leasing Mortgage Banker and TLS 2 Finance/Other includes $0.9B in Inst. and Retail Brokered CD’s; included in Finance Division segment

 December 2003 360 Banking Centers March 31, 2010 449 Banking Centers Banking Center Network MI 233 TX 91 CA 99 FL 10 AZ 16 AZ 1 FL 6 CA 42 TX 50 MI 261

449 233 10 91 16 99 3/31/10 Network 13 0 1 5 1 6 New Planned for 2010 10 0 0 4 4 2 2009 30 2 0 12 3 13 2007 28 0 1 9 4 14 2008 2006 2005 18 1 0 7 2 8 2 Arizona 25 Total 1 Michigan 3 Florida 7 Texas 12 California Banking Center Network New Banking Centers

BBB BBB+ BBB A- BBB+ A- BBB+ A- A+ A A+ AA- Fitch BBB (high) BBB- Baa3 Regions Financial BBB BB+ Baa2 Huntington BBB (low) BBB- B2 Zions Bancorporation BBB (high) BBB- Baa1 Marshall & Ilsley Baa1 Baa1 Baa1 A3 A3 A2 A1 Aa3 Moody’s A (high) A PNC A (low) A- M&T Bank A A- Comerica AA (low) A BB&T A (low) BBB Fifth Third A (low) BBB SunTrust BBB (high) BBB+ KeyCorp AA DBRS S&P Senior Unsecured/Long-Term Issuer Rating A+ US Bancorp Holding Company Debt Ratings As of 4/20/10 Source: SNL Financial Debt Ratings are not a recommendation to buy, sell, or hold securities.

Supplemental Financial Data The Corporation believes these measurements are meaningful measures of capital adequacy and used by investors, regulators, and others to evaluate the adequacy of common equity and to compare against other companies in the industry. 1 Tier 1 capital and risk-weighted assets as defined by regulation 2 March 31, 2010 Regulatory Capital, Tier 1 Capital, and Risk-Weighted assets are estimated 9.68% $56,949 $57,106 150 7 $5,511 $5,668 -- 150 7 5,816 60,680 9.58% $6,311 -- 495 $9,061 3/31/10 7.99% $59,091 $59,249 150 8 $4,720 $7,029 2,151 150 8 5,058 61,815 8.18% $7,704 2,151 495 $10,468 12/31/09 $10,773 $10,724 $10,638 Total Regulatory Capital 2 7.96% $59,432 $59,590 150 8 $4,732 $7,035 2,145 150 8 5,095 63,355 8.04% $7,735 2,145 495 9/30/09 7.55% $63,470 $63,630 150 10 $4,793 $7,093 2,140 150 10 5,139 67,124 7.66% $7,774 2,140 495 6/30/09 7.27% $67,209 $67,370 150 11 $4,888 $7,183 2,134 150 11 5,131 70,135 7.32% $7,760 2,134 495 3/31/09 Total shareholders’ equity Less: Fixed rate cumulative perpetual preferred stock Less: Goodwill Less: Other intangible assets Reconciliation of non-GAAP financial measures with financial measures defined by GAAP ($ in millions) Tangible common equity ratio Total assets Less: Goodwill Less: Other intangible assets Tangible common equity Tier 1 capital1,2 Less: Fixed rate cumulative perpetual preferred stock Less: Trust preferred securities Tangible assets Tier 1 common capital2 Risk-weighted assets1,2 Tier 1 common capital ratio 2

Supplemental Financial Data The Corporation believes this is a meaningful measure and used by investors, regulators and other to evaluate financial results and to compare against other companies in the industry. 1Excess liquidity represented by interest earned on and average balances deposited with the Federal Reserve Bank. $61,752 212 $59,522 239 $57,513 102 $53,953 107 $52,941 62 Average earnings assets Less: Average net unrealized gains on investment securities available-for-sale (0.24)% 3.18% 3.42% $48,787 $52,879 4,092 $ 413 $ 416 3 1Q10 (0.13)% 2.94% 3.07% $51,393 $53,846 2,453 $ 396 $ 398 2 4Q09 (0.16)% 2.68% 2.84% $53,919 $57,411 3,492 $ 385 $ 387 2 3Q09 (0.08)% 2.73% 2.81% $57,450 $59,283 1,833 $ 403 $ 404 1 2Q09 (0.07)% 2.53% 2.60% $59,728 $61,540 1,812 $ 385 $ 386 1 1Q09 Average earnings assets for net interest margin (FTE) Less: Excess liquidity1 Reconciliation of non-GAAP financial measures with financial measures defined by GAAP ($ in millions) Net interest margin (FTE) Net interest margin (FTE), excluding excess liquidity Average earnings assets for net interest margin (FTE), excluding excess liquidity Net interest income (FTE) Less: Interest earned on excess liquidity1 Impact of excess liquidity on net interest margin (FTE) Net interest income (FTE), excluding excess liquidity

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