Comerica (CMA) Form 4: Officer Retains 9,424 Shares After Sale

Rhea-AI Filing Summary

Comerica executive Allysun C. Fleming reported a sale of 2,100 shares of Comerica Inc. common stock on 08/08/2025 at a reported price of $67.035 per share. After the transaction, Fleming beneficially owned 9,424 shares directly. The Form 4 notes that the reported holdings include shares from employee stock plans, dividend reinvestment and restricted stock units as of the transaction date. The disclosure shows an individual officer sale rather than an acquisition or derivative activity and provides the specific share counts and price paid.

Positive

• Disclosure completeness: The Form 4 specifies the transaction date, price, quantity sold, and post-transaction holdings.
• Insider retains stake: Reporting person still beneficially owns 9,424 shares, showing continued ownership after sale.
• Compensation clarity: Filing notes holdings include employee stock plans, dividend reinvestment and restricted stock units.

Negative

• Insider sale: An officer disposed of 2,100 shares, which is a net reduction in insider ownership.
• No derivative activity disclosed: Absence of offsetting acquisitions or options reduces information about broader position changes.

Insights

Securities Analyst

TL;DR: Officer sale of 2,100 CMA shares at $67.035, leaving 9,424 shares; transaction is a disclosed insider sale with limited immediate market signal.

As a securities analyst, I view this Form 4 as a routine insider sale disclosure. The transaction code is a sale and the size is explicitly stated: 2,100 shares sold at $67.035, resulting in 9,424 shares held. There is no derivative activity reported. Impact: not impactful to valuation absent broader insider selling trends or material corporate events. The inclusion of employee plans and RSUs clarifies that part of the reported ownership arises from compensation arrangements, which is common for executives.

Corporate Governance Expert

TL;DR: Disclosure meets Section 16 requirements; sale executed by an officer, ownership remains disclosed and includes compensation-related shares.

From a governance perspective, the filing fulfills required transparency for officer transactions. The report specifies the sale quantity, price, and resulting direct ownership of 9,424 shares and notes that holdings include employee stock plan shares and restricted stock units. There is no indication of a Rule 10b5-1 plan or other contractual plan in the recorded transaction fields. Impact: not impactful on corporate governance standards, but useful for monitoring insider behavior.

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

OMB APPROVAL

OMB Number:			3235-0287
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hours per response:			0.5

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^*

Fleming Allysun C

(Last) (First) (Middle)

1717 MAIN STREET

(Street)

DALLAS TX 75201

(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)
	Executive Vice President

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

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	08/08/2025		S		2,100	D	$67.035	9,424(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

Explanation of Responses:

1. Includes shares acquired through employee stock plans, shares purchased with reinvested dividends and restricted stock units as of August 8, 2025.

Remarks:

Ex. 24 - Power of Attorney

	/s/ Nicole V. Gersch, on behalf of Allysun C. Fleming through Power of Attorney	08/12/2025
	** 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.
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 insider transaction was reported for Comerica (CMA)?

An officer, Allysun C. Fleming, reported a sale of 2,100 shares of Comerica common stock on 08/08/2025 at $67.035 per share.

How many Comerica (CMA) shares does the reporting person own after the sale?

The Form 4 reports the reporting person beneficially owns 9,424 shares following the reported transaction.

Does the Form 4 indicate the source of the reported shares?

Yes. The filing states reported holdings include shares from employee stock plans, dividend reinvestment, and restricted stock units as of the transaction date.

Was the transaction an acquisition or a sale?

The transaction is coded as a sale (Transaction Code S); no acquisitions or derivative transactions are reported.

Does the Form 4 show use of a 10b5-1 trading plan?

The provided content does not indicate that the transaction was made pursuant to a Rule 10b5-1 trading plan.