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The monetary services market is topic to regulation at all levels

of government. Modifications in federal, state and neighborhood laws can have a

significant impact on our companies. As such, Comerica Incorporated

(Comerica) is committed to diligently monitoring and participating in

the political approach.

Comerica Government Relations Group

The Government Relations Group is portion of Comericas Corporate

Compliance and Public Affairs Department. The group works closely with

the 3 significant small business segments - Enterprise Banking, Retail Banking

and Wealth & Institutional Management - to manage the companys

legislative and political activities, including the Comerica Political

Action Committee.

Comerica Political Action Committee

One way Comerica participates in the political method is through

contributions from its political action committee (PAC). The PAC

annually solicits contributions from eligible employees and makes

bipartisan contributions - all in compliance with local, state and

federal election laws - to political candidates and committees who

understand and support Comericas pro-banking, pro-business philosophy.

All political contributions and guidelines are developed and approved

by a separate PAC Board comprised of senior executives from across the

companys important business segments.

While Comerica colleagues are encouraged to participate within the

political approach on their own time, they are not pressured to make

individual contributions. Individual political contributions made by

Comerica colleagues will not be reimbursed directly or indirectly by

the company.

Comerica does not use corporate funds to make direct political

contributions to candidates for public office or groups organized to

influence political campaigns under Section 527 of the Internal Revenue

Code. From time to time, however, Comerica will contribute corporate

funds to support state and neighborhood ballot initiatives if the company

believes that passage of such initiatives will enhance the quality of

life within the communities where our customers and employees live, work

and raise their families.

For a complete list of Comerica PAC contributions between 11/1/09 and

10/31/10, please see the link below. This list is updated annually in

November.

Comerica Trade Association Memberships

Comerica belongs to several monetary services-related trade

associations across the country. Membership benefits include numerous

home business opportunities for the company and effective grassroots

advocacy on behalf of the industry. A portion of the trade association

dues that Comerica pays are used for lobbying and/or political

activities and are non-deductible under Section 162(e)(1) of the

Internal Revenue Code.

For a list of trade associations to which Comerica belongs, as of

6/24/10, please see the link below. This list is updated annually in

November.

For More Information and facts

If you have any questions about the Government Relations Group and

Comericas legislative and political activities, please contact Dan

Donohoe, Director of Government Relations, at ddonohoe@comerica.com.