CMA Form 3: Chief Risk Officer Discloses Stock, Option Holdings

Rhea-AI Filing Summary

Kristina E. Janssens, Senior Executive Vice President and Chief Risk Officer of Comerica Inc. (CMA), reported initial beneficial ownership on 09/19/2025. She directly owns 9,945 shares of common stock, including restricted stock units, and holds an employee stock option for 1,225 shares exercisable beginning 01/23/2025 and expiring 01/23/2034 with a strike price of $53.96. The filing was signed by power of attorney on 09/23/2025.

Insights

Financial Analyst

TL;DR: Routine Section 16 filing showing an officer's direct equity and an employee option; no material transaction disclosed.

The filing documents an executive-level insider holding 9,945 common shares and an employee stock option for 1,225 shares at a $53.96 exercise price. This is a standard Form 3 (initial ownership) rather than a buy/sale disclosure, so it does not provide evidence of trading activity or a change in control. For investors this simply establishes baseline insider holdings; there is no revenue, earnings, or material corporate action reported.

Corporate Governance Expert

TL;DR: Initial beneficial ownership filing by a named officer; procedural and compliance-oriented disclosure.

The Form 3 satisfies Section 16 reporting by recording the Chief Risk Officers direct ownership and outstanding employee option. The inclusion of restricted stock units and the vesting schedule note for the option are common grant terms. The signature via power of attorney indicates administrative filing practice. There are no governance issues or departures disclosed in this form.

SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person^*

Janssens Kristina E.

(Last) (First) (Middle)

36455 CORPORATE DR.

(Street)

FARMINGTON HILLS MI 48331

(City) (State) (Zip)

2. Date of Event Requiring Statement (Month/Day/Year)
09/19/2025

3. Issuer Name and Ticker or Trading Symbol
COMERICA INC [ CMA ]

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

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	SEVP - Chief Risk Officer

5. If Amendment, Date of 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

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	9,945(1)	D

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Employee Stock Option (right to buy)	01/23/2025(2)	01/23/2034	Common Stock	1,225	$53.96	D

Explanation of Responses:

1. Includes restricted stock units as of September 19, 2025.

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

	/s/ Nicole V. Gersch, on behalf of Kristina E. Janssens through Power of Attorney	09/23/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (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).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What did Kristina E. Janssens report on Form 3 for Comerica Inc. (CMA)?

She reported direct ownership of 9,945 common shares (including restricted stock units) and an employee stock option for 1,225 shares exercisable from 01/23/2025 to 01/23/2034 at a $53.96 exercise price.

What is the reporting date on the Form 3 for CMA?

The date of the event requiring the statement is 09/19/2025, and the form was signed via power of attorney on 09/23/2025.

Does this Form 3 show any stock purchases or sales by the officer?

No. This is an initial ownership report documenting holdings and an option grant; it does not disclose any purchases or sales.

Are any indirect ownership arrangements disclosed for Janssens?

No indirect ownership is disclosed. All listed holdings are reported as Direct (D) in the filing.

What vesting information is provided for the employee stock option?

The filing states the option vests in four equal annual installments based on the original grant amount beginning on 01/23/2025.