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 * Sefzik Peter L	2. Date of Event Requiring Statement (MM/DD/YYYY) 5/3/2019	3. Issuer Name and Ticker or Trading Symbol COMERICA INC /NEW/ [CMA]
(Last)        (First)        (Middle) 1717 MAIN STREET, MC 6507	4. Relationship of Reporting Person(s) to Issuer (Check all applicable) _____ Director                            _____ 10% Owner ___ X ___ Officer (give title below)          _____ Other (specify below) Executive Vice President /
(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	18156   (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)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Employee Stock Option (right to buy)	1/27/2016   (2)	1/27/2025	Common Stock	853	$42.32	D
Employee Stock Option (right to buy)	1/26/2017   (2)	1/26/2026	Common Stock	1658	$32.97	D
Employee Stock Option (right to buy)	1/24/2018   (2)	1/24/2027	Common Stock	1275	$67.66	D
Employee Stock Option (right to buy)	1/23/2019   (2)	1/23/2028	Common Stock	1340	$95.25	D
Employee Stock Option (right to buy)	1/22/2020   (2)	1/22/2029	Common Stock	2575	$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 May 3, 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 Peter L. Sefzik

Reporting Owners
Reporting Owner Name / Address	Relationships
	Director	10% Owner	Officer	Other
Sefzik Peter L 1717 MAIN STREET MC 6507 DALLAS, TX 75201			Executive Vice President

Signatures
/s/ Jennifer S. Perry, on behalf of Peter L. Sefzik through Power of Attorney		5/10/2019
** 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 control number.