[Form 4] Comerica Incorporated Insider Trading Activity

Rhea-AI Filing Summary

Christine M. Moore, EVP and Chief Audit Executive of Comerica Incorporated (CMA), reported transactions dated 08/21/2025 showing coordinated option exercise and share sale activity. She exercised 1,845 employee stock options with an exercise price of $32.97 to acquire 1,845 common shares, and concurrently sold 1,845 common shares at $66.69. After these transactions the filing lists beneficial ownership figures of 32,400 shares following the acquisition entry and 30,555 shares following the sale entry. The Form 4 notes that reported share totals include shares from employee stock plans, reinvested dividends, restricted stock units and deferred compensation stock units as of the transaction date. The filing was signed by a power of attorney on behalf of Ms. Moore on 08/25/2025.

Positive

• Option exercise executed allowing conversion of vested compensation into shares at a $32.97 exercise price
• Transparent disclosure filed on Form 4 with explanatory notes and POA signature, meeting SEC reporting requirements

Negative

• Insider sale of 1,845 shares at $66.69 reduced reported beneficial ownership from 32,400 to 30,555 shares

Insights

Securities Analyst

TL;DR Insider exercised options and sold an equal number of shares; net beneficial holdings remain substantial but decreased.

The filing documents a standard executive equity event: exercise of 1,845 options at $32.97 and an immediate sale of 1,845 shares at $66.69.

This pattern commonly reflects option liquidity and tax planning rather than a change in strategic view. Reported beneficial ownership figures move from 32,400 to 30,555 shares across the two entries. The disclosure explicitly states inclusion of plan-held shares and RSUs in totals. No new grants, departures, litigation, or material corporate developments are reported here, so impact on valuation is limited absent additional context.

Corporate Governance Expert

TL;DR The transaction is routine insider exercise and sale under employee plans, disclosed via Form 4 and executed by POA.

The record shows vested option exercises and an equal-volume sale on the same date, which is consistent with executives exercising for cash/liquidity or tax reasons. The filing was signed under a power of attorney on 08/25/2025, and the explanatory note confirms inclusion of various plan-held instruments in the ownership totals. No governance actions, policy changes, or suspicious timing are evident solely from this Form 4.

SEC Form 4

FORM 4

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

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

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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Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Moore Christine M

(Last) (First) (Middle)

COMERICA INCORPORATED

411 WEST LAFAYETTE, MC 3387

(Street)

DETROIT MI 48226

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
COMERICA INC /NEW/ [ CMA ]

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

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	EVP and Chief Audit Executive

3. Date of Earliest Transaction (Month/Day/Year)
08/21/2025

4. 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 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	08/21/2025		M		1,845	A	$32.97	32,400(1)	D
Common Stock	08/21/2025		S		1,845	D	$66.69	30,555(1)	D

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 Securities Underlying Derivative Security (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: 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
Employee Stock Option (right to buy)	$32.97	08/21/2025		M			1,845	01/26/2017(2)	01/26/2026	Common Stock	1,845	$0	0	D
Employee Stock Option (right to buy)	$67.66							01/24/2018(2)	01/24/2027	Common Stock	1,010		1,010	D
Employee Stock Option (right to buy)	$95.25							01/23/2019(2)	01/23/2028	Common Stock	785		785	D
Employee Stock Option (right to buy)	$80.17							01/22/2020(2)	01/22/2029	Common Stock	1,130		1,130	D
Employee Stock Option (right to buy)	$63.15							01/28/2021(2)	01/28/2030	Common Stock	2,150		2,150	D
Employee Stock Option (right to buy)	$60.12							01/26/2022(2)	01/26/2031	Common Stock	1,855		1,855	D
Employee Stock Option (right to buy)	$92.58							01/25/2023(2)	01/25/2032	Common Stock	1,205		1,205	D
Employee Stock Option (right to buy)	$71.16							01/24/2024(2)	01/24/2033	Common Stock	1,660		1,660	D
Employee Stock Option (right to buy	$53.96							01/23/2025(2)	01/23/2034	Common Stock	2,035		2,035	D

Explanation of Responses:

1. Includes shares acquired through employee stock plans, shares purchased with reinvested dividends, restricted stock units and stock units held pursuant to a deferred compensation plan as of August 21, 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 Christine M. Moore through Power of Attorney	08/25/2025
	** 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 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).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
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FAQ

What transactions did Christine M. Moore report on Form 4 for CMA?

She reported exercising 1,845 employee stock options at an exercise price of $32.97 and selling 1,845 common shares at $66.69 on 08/21/2025.

How many Comerica (CMA) shares did Ms. Moore beneficially own after these transactions?

The Form 4 shows beneficial ownership figures of 32,400 shares following the acquisition entry and 30,555 shares following the sale entry.

Do the ownership totals include other plan-held instruments?

Yes. The filing explicitly states totals include shares from employee stock plans, reinvested dividends, restricted stock units and deferred compensation stock units as of 08/21/2025.

Who signed the Form 4 filing for Ms. Moore?

The Form 4 was signed by Nicole V. Gersch on behalf of Christine M. Moore under a power of attorney on 08/25/2025.

Were any new grants or departures disclosed in this Form 4?

No. The filing documents option exercises and a sale; it does not disclose new grants, departures, or other corporate actions.