Initial Statement of Beneficial Ownership (3)

FORM 3	UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES	OMB APPROVAL OMB Number: 3235-0104 Estimated average burden hours per response... 0.5
	Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934 or Section 30(h) of the Investment Company Act of 1940

1. Name and Address of Reporting Person ^*

Herzog James J

2. Date of Event Requiring Statement (MM/DD/YYYY) 9/11/2019

3. Issuer Name and Ticker or Trading Symbol

COMERICA INC /NEW/ [CMA]

(Last) (First) (Middle)

1717 MAIN STREET

4. Relationship of Reporting Person(s) to Issuer (Check all applicable)

_____ Director _____ 10% Owner
___X___ Officer (give title below) _____ Other (specify below)
Treasurer and Interim CFO /

(Street)

DALLAS, TX 75201

(City) (State) (Zip)

5. If Amendment, Date Original Filed(MM/DD/YYYY)

6. Individual or Joint/Group Filing(Check Applicable Line)

_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)
Common Stock	7390 ⁽¹⁾	D

*Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)*
1. Title of Derivate Security (Instr. 4)	2. Date Exercisable and Expiration Date (MM/DD/YYYY)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form of Derivative Security: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
1. Title of Derivate Security (Instr. 4)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	4. Conversion or Exercise Price of Derivative Security		6. Nature of Indirect Beneficial Ownership (Instr. 5)
Employee Stock Option (right to buy)	1/26/2017 ⁽²⁾	1/26/2026	Common Stock	584	$32.97	D
Employee Stock Option (right to buy)	1/24/2018 ⁽²⁾	1/24/2027	Common Stock	912	$67.66	D
Employee Stock Option (right to buy)	1/23/2019 ⁽²⁾	1/23/2028	Common Stock	905	$95.25	D
Employee Stock Option (right to buy)	1/22/2020 ⁽²⁾	1/22/2029	Common Stock	1240	$80.17	D

Explanation of Responses:
(1)	Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and restricted stock units as of September 11, 2019.
(2)	The options vest in four equal annual installments (based on the original grant amount) beginning on the date indicated in this column.

Remarks:
Ex.24 - Power of Attorney for James J. Herzog

Reporting Owners
Reporting Owner Name / Address	Relationships
Reporting Owner Name / Address	Director	10% Owner	Officer	Other
Herzog James J 1717 MAIN STREET DALLAS, TX 75201			Treasurer and Interim CFO