Ownership Submission
FORM 4
Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
DINAPOLI J PHILIP
   2. Issuer Name and Ticker or Trading Symbol
COMERICA INC /NEW/ [CMA] 		5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
__X__ Director _____ 10% Owner
_____ Officer (give title below) _____ Other (specify below)
(Last)
(First)
(Middle)
500 WOODWARD AVE., 31ST FLOOR		 3. Date of Earliest Transaction (Month/Day/Year)
10/03/2005
(Street)

DETROIT, MI 48226		 4. If Amendment, Date Original Filed(Month/Day/Year)
 6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1.Title of Security
(Instr. 3)		 2. Transaction Date (Month/Day/Year) 2A. Deemed Execution Date, if any (Month/Day/Year) 3. Transaction Code
(Instr. 8)		 4. Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4 and 5)		 5. Amount of Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 3 and 4)		 6. Ownership Form: Direct (D) or Indirect (I)
(Instr. 4)		 7. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V Amount (A) or (D) Price
Common Stock 10/03/2005   A   359 (1) A $ 59.47 194,342 (2) D (3)  
Common Stock               50,176 I by DiNapoli Family L.P.
Common Stock               5,871 I by D&D Ranch
Common Stock               64,575 I by DDD Partners

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Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 3)		 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (Month/Day/Year) 3A. Deemed Execution Date, if any (Month/Day/Year) 4. Transaction Code
(Instr. 8)		 5. Number of Derivative Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4, and 5)		 6. Date Exercisable and Expiration Date
(Month/Day/Year)		 7. Title and Amount of Underlying Securities
(Instr. 3 and 4)		 8. Price of Derivative Security
(Instr. 5)		 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 4)		 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 4)		 11. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares
Director Stock Option (right to buy) $ 29.08             05/17/1997 05/17/2006 Common Stock 1,500   1,500 D  
Director Stock Option (right to buy) $ 40.09             05/16/1998 05/16/2007 Common Stock 1,500   1,500 D  
Director Stock Option (right to buy) $ 65.13             05/15/1999 05/15/2008 Common Stock 1,500   1,500 D  
Director Stock Option (right to buy) $ 62.75             05/21/2000 05/21/2009 Common Stock 1,500   1,500 D  
Director Stock Option (right to buy) $ 44.13             05/19/2001 05/19/2010 Common Stock 2,000   2,000 D  
Director Stock Option (right to buy) $ 57.15             05/22/2002 05/20/2011 Common Stock 2,500   2,500 D  
Director Stock Option (right to buy) $ 64.5             05/21/2003 05/21/2012 Common Stock 2,500   2,500 D  
Director Stock Option (right to buy) $ 43.63             05/20/2004 05/20/2013 Common Stock 2,500   2,500 D  
Director Stock Option (right to buy) $ 53.87             05/18/2005 05/18/2014 Common Stock 2,500   2,500 D  
Restricted Stock Units $ 0 (4)             08/08/1988(5) 08/08/1988(5) Common Stock 319   319 D  

Reporting Owners

Reporting Owner Name / Address Relationships
 Director  10% Owner  Officer  Other
DINAPOLI J PHILIP
500 WOODWARD AVE.
31ST FLOOR
DETROIT, MI 48226		   X      

Signatures

 /s/ Robert W. Spencer, Jr., on behalf of J. Philip DiNapoli   10/05/2005
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 4(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) Stock units acquired under a deferral plan. The units are being reported in Table I because they are distributed in the form of common stock, on a one-for-one basis.
(2) 170,288 shares are held in a revocable living trust for estate planning purposes and 15,241 are held in an individual retirement account.
(3) Includes stock units held pursuant to deferred director plans, restricted stock units, and shares purchased with reinvested dividends as of October 4, 2005.
(4) Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.
(5) The restricted stock units vest one year after the date of grant. Vested shares are settled one year after cessation of service on the board.

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