Darlene Persons - Director of Investor Relations Ralph Babb – Chairman Beth Acton - Chief Financial Officer Dale Greene - Chief Credit Officer

Steven Alexopoulos – JP Morgan Craig Siegenthaler – Credit Suisse David Rochester – FBR Matthew O’Conner – Deutsche Bank Gary Townsend – Hill Townsend Capital Heather Wolfe – UBS Jeff Davis – FTN Equity Capital Markets Ken Usdin – Bank of America-Merrill Lynch Brian Foran – Goldman Sachs Brian Klock – KBW Michael Rose – Raymond James Gary Tenner – Soleil Securities

(Operator Instructions) I would like to welcome everyone to the Comerica Fourth Quarter 2009 Earnings Conference Call. Ms. Darlene Persons, you may begin the conference.

Welcome to Comerica’s Fourth Quarter 2009 Earnings Conference Call. This is Darlene Persons, Director of Investor Relations. I am here with our Chairman, Ralph Babb, our Chief Financial Officer, Beth Acton, and Dale Greene, our Chief Credit Officer. A copy of our earnings release, financial statements and supplemental information is available on the SEC’s website as well as on our website. Before we get started, I would like to remind you that this conference call contains forward looking statements and in that regard you should be mindful of the risks and uncertainties that can cause future results to vary from expectations. I refer you to the safe harbor statement contained in the earnings release issued today, which I incorporate into this call as well as our filings with the SEC. Also, this conference call will reference non-GAAP financial measures. In that regard I would direct you to the calculation of these measures within the earnings release and presentation. Now I’ll turn the call over to Ralph.

We saw many encouraging signs in the fourth quarter including improved credit metrics, continued strong deposit growth, a slower pace of decline in loan demand, and a notable increase in the net interest margin. These positive developments lead us to believe our core fundamentals will continue to show improvement in 2010. We are pleased to see broad based improvement in credit quality. Net credit related charge-offs decreased $14 million in the fourth quarter. Non-performing assets decreased $13 million and the provision for loan losses decreased $54 million. Non-accrual loans were charged down to 44% as of December 31, versus 41% at September 30. Our watch list loans were down $520 million. We believe these improved credit metrics are the result of our diligent management of credit throughout this economic cycle. With unemployment at 10% business owners and managers, as well as consumers remain, cautious. This is reflected in the subdued loan demand and in our core deposits which increased $935 million from the third quarter. However, our customers are conveying a more confident tone and we are seeing more loans in the pipeline. New and renewed loan commitments totaled $9.8 billion in the fourth quarter. Combined with our strong capital levels and dedicated colleagues we believe we are ideally positioned to develop new relationships and expand existing ones as the economy continues its recovery. Our net interest margin increased 26 basis points to 2.94% in the fourth quarter. Excluding excess liquidity, represented by average balances deposited with the Federal Reserve Bank, the net interest margin would have been 3.07%. We continue to focus on expense controls. Our workforce has been reduced by 8% from 2008 even as we added 10 new banking centers in 2009. Our capital position remains strong. Our Tier 1 capital ratio is estimated to be 12.46% at December 31. In addition, the quality of our capital remains solid as evidenced by a tangible common equity ratio of 7.99%. With regard to the $2.25 billion in preferred stock, we still plan to redeem it at such time as feasible with careful consideration given to the economic environment. It remains a top corporate priority. In summary, we believe the future is brighter and that current opportunities are ahead of us because of the many positive signs we have seen in the fourth quarter. These positive signs are reflected in the breadth of improvement we have seen in credit quality as well as in our strong deposit growth, the less subdued loan demand and in our increasing net interest margin. Our customers are expressing more optimism and we share that optimism with them as the economy continues its recovery. Now I’ll turn the call over to Beth and Dale who will discuss our fourth quarter results in more detail.

As I review our fourth quarter results I will be referring to slides we’ve prepared that provide additional details on our earnings. Turning to slide three, we outline the major components of our fourth quarter and full year results compared to prior periods. Today we reported a fourth quarter 2009 net loss of $29 million after preferred dividends of $33 million the net loss applicable to common stock was $62 million or $0.41 per diluted share. Slide four provides an overview of the financial results for the fourth quarter compared to the third quarter. Credit quality metrics improved consistent with our outlook. Non-performing assets declined $13 million and the inflow to non-accrual slowed by $95 million to $266 million. Net credit related charge-offs decreased to $225 million and the provision declined to $257 million compared to $311 million in the third quarter. The net interest margin in the fourth quarter increased 26 basis points to 2.94%. Reduced deposit rates, maturing of higher cost time deposits, and improved loan spreads all contributed to the increase. The low return on excess liquidity had a 13 basis point impact which I’ll describe in more detail in a minute. We had very strong deposit generation again in the fourth quarter with core deposits increasing $935 million including a $1.2 billion increase in non-interest bearing deposits. Average earning assts decreased $3.6 billion including a $2 billion decline in loan outstandings. Our customers continue to be cautious in the current economic environment. Average other earning assets, primarily Federal Reserve Bank deposits and investment securities decline $1.6 billion as average excess liquidity was reduced. Non-interest income decreased due to a $97 million decline in securities gains consistent with our outlook. We continued to carefully control expenses. The fourth quarter results reflected a decreased in regular salaries and incentives which were more then offset by an increase in severance expense relating to a planned reduction of 300 full time equivalent positions. Our workforce has been reduced by about 850 positions or 8% since December 2008. Full year 2009 non-interest expenses decreased 6% from 2008. Our capital position is strong and was further enhanced in the fourth quarter. The Tier 1 capital ratio increased to an estimated 12.46% at December 31. In addition, the quality of our capital is solid as evidenced by our tangible common equity ratio of 7.99%. Turning to slide five, average loan outstandings declined at a slower pace in the fourth quarter compared to the third quarter, consistent with post-recessionary environments we had low loan demand in all of our geographic markets as customers continued to de-leverage as they cautiously manage their businesses. Decreased average outstandings in the fourth quarter were noted in virtually every area with the largest declines in middle market, global corporate banking and commercial real estate. Line utilization was 46.8% in the fourth quarter down slightly from the third quarter. As shown on slide six, we have very strong core deposit growth again in the fourth quarter. We had growth in Texas, Western and Florida markets and all commercial lines of business. Average core deposits increased $935 million including a $1.2 billion increase in non-interest bearing deposits. While deposit rates are significantly lower today, I’m pleased to say that to date we’ve retained the vast majority of the balances of maturing customer CDs, many of which were put on in late 2008 at rates over 3%. Deposit pricing conditions remained competitive in the fourth quarter and we believe we’ve hit rate floors on a number of our products. However, we were able to selectively decrease rates in certain deposit categories. As outlined on slide seven, the net interest margin increased 26 basis points in the fourth quarter to 2.94%. Excluding the impact of excess liquidity the net interest margin would have been 3.07% in the fourth quarter, an increase of 23 basis points from the third quarter. The increase was primarily the result of lower core deposit rates, maturing higher cost customer CDs and other timed deposits, and a decrease in excess liquidity. In the fourth quarter, excess liquidity had an approximately 13 basis point negative effect on the margin compared to a 16 basis point impact in the third quarter. Excess liquidity was represented by an average of $2.5 billion deposited with the Federal Reserve in the fourth quarter, down from an average $3.5 billion in the third quarter. With the maturities of wholesale funding and expected loan growth we expect excess liquidity will dissipate in the first half of the year. This excess liquidity is above and beyond the investment securities portfolio which will continue to provide a reservoir of liquidity. Turning to slide eight, we focus on expense management on a daily basis. Our largest expense item is salaries and therefore management of staff levels is key. As you can see on the slide, we have consistently reduced personnel over the past several years even while we were opening new banking centers. In 2009, in response to the recession and as part of our ongoing efforts to leverage technology and maximize productivity to support growth, full time equivalent staff decreased by approximately 850 employees or 8%. In 2010 we expect to achieve a further reduction of about 300 positions or about 3% of the total workforce which will largely be completed by mid year. These positions are across all lines of business and geographies. In conjunction with this action, we incurred a severance charge of $11 million in the fourth quarter. Annualized salary savings of about $16 million related to this action are expected going forward. Now Dale Greene, our Chief Credit Officer, will discuss credit qualities, starting on slide nine.

We saw broad based improvement in our credit metrics in the fourth quarter. As expected, fourth quarter net credit related charge-offs and the provision for credit losses improved from third quarter levels. Economic conditions continued to be challenging but we are seeing more encouraging signs that things are improving. Net credit related charge-offs were $225 million in the fourth quarter, a $14 million reduction from the third quarter. Net charge-offs included $62 million in the commercial real estate line of business, primarily related to residential real estate development, down from $91 million in the third quarter. The decline in commercial real estate charge-offs reflects the wind down of the California local residential real estate portfolio and the fact that we believe we have been taking the necessary charges to reflect declining values over the past two years. We also continue to see values stabilize in select markets. Provision for credit related losses of $259 million was $54 million less then the third quarter. The provision exceeded net charge-offs by $34 million compared to $74 million in the third quarter reflecting the improvement in overall credit performance. The allowance for loan losses was 2.34% of total loans, an increase of 15 basis points from the third quarter. The allowance for loan losses was 83% of non-performing loans. Turning to slide 10, total non-performing assets declined $13 million to $1.3 billion. Importantly, the inflow to non-performing assets decreased by $95 million in the fourth quarter. Loans past due 90 days or more and still accruing declined $60 million to $101 million. Foreclosed property held relatively stable. Other real estate expenses in the fourth quarter increased to $22 million from $10 million in the third quarter. This reflects write downs related to updated appraisals. The average carrying value of these properties is now well below 40% of the original contractual loan amount. Also, we believe that the market is starting to stabilize. Therefore, we expect quarterly ORE expenses going forward to be less then the fourth quarter level. Our watch list loans decreased by $520 million to $7.7 billion at the end of the fourth quarter. This reflects improvements in our portfolio in all geographic markets and across virtually all lines of business. On slide 11 we provide information on the makeup of non-accrual loans. The largest portion of the non-accrual loans continues to be commercial real estate which consists primarily of residential real estate development loans. Commercial real estate non-accrual loans decreased by $47 million in the quarter. Non-accruals also decreased in middle market by $17 million. Personal banking, which falls within other business lines, saw a $25 million increase in non-accruals as the weak economy has taken a toll on some of our residential mortgage customers. Because these are primarily seasoned mortgages, the loss content remains low. During the fourth quarter 2009, $266 million of loan relationships greater than $2 million were transferred to non-accrual status, a reduction of $95 million from the third quarter. Of these inflows, commercial real estate line of business contributed $64 million down from $211 million in the third quarter. Middle market at $85 million a small decrease from the third quarter. Inflows increased modestly in several lines of business such as small business, global corporate banking, and technology and life science from low levels. Slide 12 provides further detail on our non-accrual loans. Collateral values on non-accrual loans are reviewed every quarter as part of our credit quality review process. We have written down non-performing loans by 44% compared to 34% a year ago. The carrying value plus the reserve reflect current market conditions. We had $34 million in total troubled debt restructurings or TDRs. This included $18 million in reduced rate loans, primarily residential mortgages, $5 million in other non-performing TDRs, and $11 million in performing TDRs. In the fourth quarter we sold $11 million in loans, four loans totaling $10 million were non-performing. The average price was close to carrying values plus reserves. We have seen a firming of prices, particularly for distressed syndicated debt. We continue to pursue loan sales on a one off basis. On slide 13 we provide a breakdown of net credit related charge-offs by office of loan origination. Net charge-offs in all four major geographic markets declined in the fourth quarter. Within the Midwest which made up 43% of the total, middle market charge-offs declined. Small business charge-offs were relatively stable and we saw small increases in private banking and global banking. Western market charge-offs made up 38% of the total. The decrease from the third quarter was driven by a decline in residential development related charge-offs as well as global corporate banking. Middle market posted an increase from the third quarter. Texas net charge-offs returned to a relatively low level with no particular area of concentration. As far as Florida, net charge-offs declined again in the fourth quarter as there were no additional significant write downs on the condo portfolio. Other markets net charge-offs increased with no particular geographic or industry focus. Slide 14 provides detail on net loan charge-offs by line of business. The commercial real estate line of business charge-offs declined while middle market increased as expected. Charge-offs for wealth and institutional management, small business, and personal banking were relatively stable. On slide 15 we provide a detailed breakdown by geography and project type of our commercial real estate line of business which declined $194 million from the prior quarter. There is further detail provided in the appendix to these slides. At December 31, 22% of this portfolio consisted of loans made to residential real estate developers secured by the underlying real estate. Michigan outstandings of $620 million represented 13% of the portfolio and were down $142 million from a year ago. Florida outstandings of $553 million represents 11% of the portfolio and were down $160 million from a year ago. As shown on slide 16, as of the end of the fourth quarter we reduced residential real estate development exposure by $1.2 billion or 54% since June 2008. Total single family construction outstandings were down $785 million or 59% from June 2008. Turning to slide 17, we display project type and geographic breakdown of net charge-offs for the commercial real estate line of business. Consistent with the decline in total commercial estate non-accrual loans, and decline in inflows to non-accrual loans, we had a $29 million or 33% decrease in net charge-offs in the fourth quarter for a total of $62 million. Residential real estate development charge-offs decreased by over 50% in the fourth quarter. We have prices for single family homes stabilize and even increase in select markets. However, land prices remain soft and in some locations continue to decline. Charge-offs in non-residential real estate construction segment increased in the fourth quarter. The majority can be attributed to a single transaction secured by entitled land in California. While we continue to see softness we believe that non-residential real estate will see far fewer defaults and much lower loss content then the residential construction segment. In fact, we had only one non-residential commercial real estate loan over $2 million transferred to non-accrual in the fourth quarter. Total commercial real estate related charge-offs decreased in Western, Texas, and other markets, Midwest was stable. As far as Florida, charge-offs have trended downward for the last two quarters. We have limited land exposure in Florida and single family exposure has been managed down for some time. The issues in Florida are primarily related to condo exposure which totaled about $100 million at December 31, down from about $125 million at the end of September. Condo closings are occurring but at a very modest level. Slide 18 provides an overview of our consumer loan portfolio. This portfolio is relatively small, representing less than 10% of our total loans. These loans are self originated and are part of a full service relationship. The residential mortgages we hold on our balance sheet are primarily associated with our private banking customers. Net charge-offs for residential mortgages decreased again in the fourth quarter. The home equity loan portfolio has held up relatively well with a slight increase in charge-offs in the fourth quarter and 30 and 90 day delinquency rates improved. Slides detailing our auto dealer and automotive supplier portfolio can be found in the appendix. Both portfolios continue to perform well. As far as the auto supplier portfolio, we continued to reduce our loan outstandings and it now represents only 2% of our total loans. Non-accrual loans and net-charge offs declined significantly in the fourth quarter. The auto dealer average outstandings have declined $1.4 billion or 32% over the past year in line with falling sales volumes of new cars. We continue to have excellent credit quality in this portfolio. To conclude on credit, we conduct in depth reviews of all of our watch list credits at least quarterly to ensure that we have an appropriate work out strategy as well as reserves and carrying values that reflect our collateral assessment. This proactive action has resulted in a current carrying value of non-performing loans of 56%. We are pleased with the improvement in credit metrics in the fourth quarter. These results, as well as an improving macro economic statistics support our outlook for net credit related charge-offs of $775 to $825 million for 2010. We expect the provision for credit losses to slightly exceed net charge-offs for the year. Now I’ll turn the call back to Beth.

Turning to slide 19, our Tier 1 capital ratio is well in excess of the well capitalized threshold as defined by the regulators and it has increased in each of the past five quarters. Turning to slide 20 and the tangible common equity ratio, we have maintained a solid capital structure with a large component of common equity for many years. Our tangible common equity ratio, which was 7.99% at the end of the fourth quarter, increased from the third quarter and historically has been well above the average ratio of our peer group. Slide 21 provides our expectations for 2010 which is based on a modestly improving economic environment. We expect subdued loan demand for a while longer as loan growth typically lags other positive economic indicators. We believe will achieve single digit period end to period end loan growth. We expect the securities portfolio will remain at the current level. Based on the assumption that there will not be an increase in the Fed Funds rate in 2010 we expect that the net interest margin will increase to 3.15% to 3.25% as a result of maturities of higher cost CDs and wholesale funding and a reduction in excess liquidity. In addition, we expect the margin will continue to benefit from improved loan pricing. Our outlook is for net credit related charge-offs of $775 to $825 million. Provision is expected to be slightly in excess of net charge-offs. Non-interest income excluding 2009 securities gains is expected to be flat as increases in core fee income are offset by 2009 non-recurring items such as gains on the repurchase of debt. The expected reduction of pension, FDIC and ORE expense as well as the continued careful control of discretionary costs is expected to result in low single digit decrease in expenses. Overall, the many positive signs we saw in the fourth quarter such as improved credit metrics, continued strong deposit growth, a slower pace of decline in loan demand, and a significant increase in the net interest margin, lead us to believe we will continue to see improvement in our core operating fundamentals in 2010. Now we’d be happy to answer any questions you may have.

(Operator Instructions) Your first question comes from Steven Alexopoulos – JP Morgan Steven Alexopoulos – JP Morgan: To drill down into the provision guidance a bit, I believe its full year provision exceeding net charge-offs. Do you expect in the later quarters of 2010 to actually start providing below net charge-offs?

My sense of it is that with the very broad based improvement and the metrics that we saw in the fourth quarter, there were a number of them that we’ve talked about, that we should continue to see that delta. You saw the reduction actually between the charge-offs and provision fall rather substantially from quarter to quarter last quarter. My guess is that we continue to see the economy show steady improvement that we’d probably be at that point. Steven Alexopoulos – JP Morgan: Given what we saw with the watch list this quarter, how should we think about the trend in inflows into non-accrual? Should that just gap down here or do you expect it to be more gradual through the year?

I don’t suspect that it will be like falling off a cliff but I do think that we will in fact see gradual improvement as the economy continues to improve. Clearly everything that we’re seeing points to that. Hopefully that is in fact the case. Steven Alexopoulos – JP Morgan: The guidance for the single digit decrease in non-interest expense is that off the base of the $1.649 billion?

That’s correct.

Your next question comes from Craig Siegenthaler – Credit Suisse Craig Siegenthaler – Credit Suisse: We just want to give a little push back on the guidance for loan growth of mid single digit point to point in 2010. We know there’s historical correlation between the inflection point economic growth which happened this year and loan growth recovery next year. Given that your loans are still shrinking at a pretty rapid pace and this recession was deeper and longer then most, how can you make us feel a little more comfortable about positive loan growth for 2010?

The guidance for low single digit growth from the period end, 12/31/09 to 12/31/10. When you look at how we’re thinking of it, it will be pretty muted if you think about loans in the first half of this year. We’ll see more rise toward the end of this year. We’re expecting a fairly typical pattern which is probably two to three quarters after GDP turns positive we start, as an industry, seeing C&I loans. We believe that could start toward the end of the second quarter, in the second quarter. Perhaps pick up pace, our expectation, in the second half. We’re talking low single digit period end to period end growth. Really muted in the first half with more growth in the second. The other point is we were pleased that while loans were down in the fourth quarter that they were down at a slower pace then they were in the third. So that’s at least progress toward what I just described. Craig Siegenthaler – Credit Suisse: Is there anything you can point to quantitatively or fundamentally that you’re seeing a turn with your clients or demand for C&I loans. Anything that you can point to that makes us see that it turns.

I think what we’re seeing is we’re starting to see some good activity, we’re starting to see some backlogs grow, clients are starting to talk a little bit more optimistically. We’re starting to hear the thing, starting to see the things that would suggest that our loan volume should start to improve. I don’t suspect that you’ll necessarily, as Beth indicated, see that as much early in the year as later in the year. The other issue is, as you know, we’ve got a reasonably sized dealer book that’s come down quite a bit because of sales volumes. Sales volumes are rebounding nicely; dealer inventories are at very low levels. I think we’re going to start to see that business grow a bit as well not only with existing clients but obviously with new clients.

Clearly in the lines you’re seeing new lines as well as renewed lines that are supporting what Dale and Beth said. The customers are getting prepared and feeling a little more positive about what’s going on and they want to be in a position to seize the opportunity as it moves forward.

Your next question comes from David Rochester – FBR David Rochester – FBR: Can you qualify a little bit more where the pipeline is building, which products and the geographies?

Clearly middle market and particularly in Texas and California we’re seeing good activities. We’re seeing some opportunities certainly in the large corporate space, particularly in Texas where obviously we’ve been now headquartered for the last couple of years. I’d say it’s fairly broad based. As I said, the dealer book I think we’re going to start seeing some activity there as dealers build inventory. As you know, that’s been a very good business for us through the years. Clearly with the banking centers we’ve got with more of a focus on the small business side we would hope to see more small business growth. David Rochester – FBR: At this point not really seeing it on small business side, more on the middle market side?

More middle market but I think we’re also starting to see it in some other areas as well. Clearly our focus as we said for a long time we’re more in the middle market space, we like that space. We have great opportunities given our market share in Texas and California. I think there’s tremendous upside with the kind of banking we do and with the model we bring to the table. David Rochester – FBR: Do you happen to know what percentage of the loans are sitting on the floors at this point and what percentage of the book has been renewed at those higher spreads?

It’s only about $3 billion of our $42 billion loan book that has floors so it’s not a significant impact. The second is on the re-pricing, I think as we get through the balance of this year that we will have effectively re-priced the entire loan portfolio. We saw a good improvement in loan spreads in ’09 and part of our margin guidance improvement in 2010 entails working through the portfolio of re-pricing so that we’ll see further loan spread expansion this year as well.

Your next question comes from Matthew O’Conner – Deutsche Bank Matthew O’Conner – Deutsche Bank: I’ll take the other side of the loan growth argument and I think when it comes back it’ll probably come back both sooner and a little bit more than expected. But the tricky thing to figure out is who’s in a position to get this growth. We can see that you have the mix that would suggest that you should get it. Are there any metrics that you can provide that suggest you’ve maintained or gained market share in terms of sales staff or increasing credit commitments?

As we have focused on the current environment and as you know in moving our headquarters a couple years ago down to Texas, the focus has been the fast growing markets for us which are both Texas and California. Today we believe we have capacity in California and we’re continuing to look at where we are here and how we want to move forward with the resources necessary to be prepared for the turn. That’s part of the overall strategy and was when we moved here even before the downturn in the economy. Matthew O’Conner – Deutsche Bank: Any metrics on the credit commitments, you gave us the line utilization but you can often measure some market share gains just by looking at the total commitments.

We don’t have any of those numbers.

We did display on one of our slides, slide 25 that talks about new and renewed commitments so clearly we’re still doing a lot of business with not only existing customers but with new customers as well. That’s one measure that we certainly provide on a quarterly basis. Matthew O’Conner – Deutsche Bank: We’re getting more and more estimates on what the overdraft and NSF regulatory changes might be at the banks. I think it’s a much more modest impact for you then for some. Do you have a rough estimate on what that might be?

We’re still evaluating what’s going on in the competitive landscape there and have not formulated the big plans at this juncture. As you said, it’s a significantly smaller part of our revenue then for many others. Its something we will manage through and make sure we’re competitive. Matthew O’Conner – Deutsche Bank: Have you disclosed what NSF fees are relative to your total service charges?

It’s less than 1% of revenue, related to retail.

Your next question comes from Gary Townsend – Hill Townsend Capital Gary Townsend – Hill Townsend Capital: Your capital ratios look awfully strong, what about repaying the TARP at this point?

As I mentioned earlier, we’re focused on that as one of our top priorities and we’re watching the economy and we’re watching the positive signs that we’re seeing to evaluate where we and when we will be able to do that. Gary Townsend – Hill Townsend Capital: 2010?

We haven’t set a date for it. We continue to monitor it and like I said it is one of our top priorities.

Your next question comes from Heather Wolfe – UBS Heather Wolfe – UBS: On C&I, I know that migration in this product is notoriously lumpy, what are you thinking in terms of peak losses in NPLs have we seen it, is it this quarter or do you expect some further deterioration as we move through 2010?

If you look at any metric you want and put them all together I think that not only have we said we thought the fourth quarter would show improvements, certainly we said we’d see improvements in charge-offs but across the board we’ve seen just steady improvements. When I looked at the watch category down $520 million quarter over quarter and I look at the components of it, I feel pretty good that in the C&I book not only are we on top of it but we should see steady improvements. I’m very confident in that. That book has held up well for us.

To amplify what Dale said, the really good thing about the watch list decline is its broad based, it’s across all of our geographic markets including Michigan, and it’s across virtually all of our business lines. I think that is a very important factor.

Which I think is very reflective of the markets we’re in which is one the key strategies for us in the businesses we’re in.

Your next question comes from Jeff Davis – FTN Equity Capital Markets Jeff Davis – FTN Equity Capital Markets: In terms of the low rate environment how much, since credit for your company and many others looks like it has peaked or is on the verge of peaking. How important was the zero rate interest policy from the Fed in terms of borrowers getting over the hump. Secondly, consensus is for limited rate hikes late this year and into 2011 but if rates go up say 300 bps does that matter for credit in 2011?

I don’t think there’s any doubt that particularly in the real estate side, single family in particular, that a lot of the programs and the rates are one piece that have certainly helped, I don’t think there’s any question. On C&I I think in general that has been probably less of an issue then is has been for real estate. I wouldn’t discount it as not being important. I think it’s a little less significant in the C&I book then for the real estate book for us. As to a rate hike and its impact, it’s hard to evaluate. I think people probably at some point would anticipate that, if their plans would incorporate that. I think as the economy gets better most of our customers have rationalized the devil out of their expense structure. They’ve lived with an environment whether it be in Michigan or anywhere else for two or more years of difficulty. I think they’re poised to take advantage of revenue growth. I think we will see revenue growth and I think that will help accommodate whatever happens on the rate side.

As rates are going up as much as you’re just describing there, hopefully that means there’s a good strong growth underlying it which will be helpful to what Dale just described. In addition, obviously a rate rise also helps us from an interest rate management standpoint. Rising rates probably means a better economy which is good news for Comerica and our customers. Jeff Davis – FTN Equity Capital Markets: In terms of FDIC deals what are your thoughts on 2010?

We continue to monitor what’s available and as we’ve said many times in the past, the key for us is it has to fit our model in our markets and we’re very careful as we evaluate that. We’re looking at them to fit into our longer term strategy not as a transaction in the short term. Jeff Davis – FTN Equity Capital Markets: Would it be fair say since most that are failing if not all of them have a very heavy real estate dent all else equal probably wouldn’t be of interest?

Certainly that would be an issue for us as we look at it. We would not want to take on severe risk in any kind of acquisition like that.

Your next question comes from Ken Usdin – Bank of America-Merrill Lynch Ken Usdin – Bank of America-Merrill Lynch: I noticed you sold a little bit of loans this quarter, $10 million or so. I’m wondering if you’re seeing any incremental opportunities for loan sales how that mark is acting and whether or not that would fit your strategy to continue to manage the loss content.

Yes, yes, and it looks good. I would have to say, particularly as we indicated on more of the syndicated side, clearly the secondary market is looking better. We always are evaluating opportunities. Across the board I would say there’s more interest in distressed asset sales, whether its packages of deals or one off deals. In a lot of cases let’s say its real estate, the prices of real estate and the write downs have been so significant the people are now starting to say maybe the bottom has been reached or maybe we’re on the upside of that depending on the market. Very, very good activity. We continue to look at that as one of our strategies to shed assets, certainly problem assets. We’ll continue to do that. Ken Usdin – Bank of America-Merrill Lynch: Could you give us a little color on two more items? First of all, I noticed that there was no provision for Florida this quarter and was wondering how confident are you maybe that you’re really passed the peak in Florida? Secondly, if you could drill down a little bit into income producing CRE and give a little bit more color about why you’re continuing to feel so confident about that part of the book?

Florida, in terms of the real estate side, is only $500 million. For us, condos were the issue, that’s down to $100 million. We’ve taken the marks there that I think we need to take. Condos are selling, although at lower prices and lower absorptions but they are selling. That market is actually starting, depending which part of Florida you’re talking about, we’re in the markets we want to be in that I think are coming back nicely. We feel pretty good about what we’re seeing there, feeling very good about the marks we’ve already taken. That’s why Florida, we’re feeling very good about at this point. Across the board, income producing properties for us, again a lot of our construction loans have reached completion or are nearing completion. The construction piece is behind us. We’re seeing in many cases that the discounted cash flows are sufficient to structure deals into a mini perm. We have numerous examples of deals that we’ve done that with. Not only are we able to structure into mini perms we’re able to get, in many cases, more collateral, cross collateralize. We’re also usually able to get better rates and other structure enhancements. It’s a good opportunity right now for us as these loans are completed to really strengthen our position and that’s what we’ve done.

To reinforce Dale in his script has indicated that we only had one non-residential commercial real estate loan over $2 million transferred to non-accrual in the fourth quarter. There’s not a big pile that’s waiting to come in or has come in so that’s a good indicator as well.

Your next question comes from Brian Foran – Goldman Sachs Brian Foran – Goldman Sachs: If I think about your deposit and how this loan growth issue is going to play out, should we expect a quarter at some point down the road where TDAs shrink, loans aren’t growing yet but that’s actually a somewhat bullish sign because that’s the first source of corporate actually investing they draw down on their own cash?

That’ll be exactly what you’ll see because people are keeping their liquidity and they’ve got it in deposits, they’re waiting for the turn, and they will spend that before they begin to draw down on their lines. Brian Foran – Goldman Sachs: If I look at your slide six, I know people don’t raise their hand and define their deposits as excess liquidity versus market share. Do you have a sense of how much of your deposit growth over the past year especially has been market share gains versus excess liquidity from your customers?

It’s been a blend. Back to the mix of our business, even though we’ve been in a downturn, being in a couple of the high growth markets has been a plus there. As I mentioned earlier, people are being very cautious including picking up new customers. I don’t have a number on the exact mix of that.

On the slide you referred to, you can see we’ve been growing DDA actually for; our chart goes back to the fourth quarter of ’07. As you can see, through this recession, the liquidity you talked about an acceleration of that growth. We have been growing DDA it’s just been growing faster with the environment that we just described. Brian Foran – Goldman Sachs: When we think about your capital ratios, TCs, best in class, risk weighted assets working against you so the Tier 1 ex. TARP comment they’re all good but not at the top of the stack. Do you feel like you get credit for that when you speak with the constituents you’re dealing with especially around the TARP issue? Your risk ratings are high but your charge-offs and NPA trends wouldn’t suggest that necessarily is a riskier balance sheet.

I think it’s well understood. Everybody understands where we are and that’s the reason, as Beth indicated in her comments, to a solid and a strong capital base and being at the 7.99% on the equity side.

Your next question comes from Brian Klock – KBW Brian Klock – KBW: The commercial real estate portfolio, the income producing piece, how much of that comes up for renewal in 2010 that maybe you could be concerned with but the collateral values on those properties that come up for renewal this year?

Off the top of my head I can’t tell you exactly what would come up for renewal this year. Since we haven’t really made a new construction loan in the two and a half, three years and we typically make them for two to three years a lot of them have already come up for renewal and we’ve dealt with them. As it relates to valuations, we’re doing valuations all the time. I’m not particularly concerned about valuations having necessarily big impact on us because we’re very current on those as you know. For the most part, we’re seeing generally just improvements in commercial real estate space, particularly income producing. We’re seeing projects that are leasing up nicely. Obviously in those cases where they’re not we’re dealing with them. I’m not really overly concerned about that, I think because of the fact that we haven’t made a new one in some time a lot f them we’ve already dealt with. There’s not that many more that I think we have to face this year. Brian Klock – KBW: In the fourth quarter the effective tax rate was a little bit higher then I thought. Was there anything one time in there or anything that drove that or is it still related to the Bowley and the other low income housing credits as the adjustments there?

There are no unusual tax items in the fourth quarter. In the second and third we did have some settlements and some anticipation of tax refunds. There’s nothing unusual in the fourth quarter. I think the guidance we gave for 2010 on how the tax is calculated is consistent with that we’ve been saying.

Your next question comes from Michael Rose – Raymond James Michael Rose – Raymond James: I saw the shared national credit portfolio continues to come down; can you talk about any noticeable credit trends in that book?

That portfolio has performed nicely for us, as you know. We’re moving more and more to relationships and less transactions. In terms of the credit metrics, they’re slightly improved from where they were in the last quarter. You saw the results of our SNC portfolio as it relates to the SNC exam pretty much all reflected in the third quarter. Its granular, it’s across a number of lines of business and so forth. My comments on the SNC portfolio is it’s just a piece of our business where we want to develop further the relationships. I think all in its performing very satisfactorily. Michael Rose – Raymond James: Can you talk about your energy portfolio in general and any demand improvement that you might see over the coming year?

The energy book has performed very well for us. We are very active in terms of how we manage the price deck, we meet monthly on that and reset it as appropriate. We’re more focused on gas then we would be on oil, energy prices have come back nicely. We have opportunities there to do more business, I think as the capital markets continue to improve a lot of the credits that we provided financing for will find opportunities to go to the capital markets which was always their intent. It’s been a very good book. We’re not at the low end, we’re not at the high end, we’re very focused on the mid cap types of companies that I think are very strong, with very solid properties behind them.

Your last question comes from Gary Tenner – Soleil Securities Gary Tenner – Soleil Securities: Regarding the outlook in terms of the charge-off and provision trends for 2010, given the trends we saw in the fourth quarter which seem to be pretty universally positive for you, the way the current NPAs are marked I still find it a little surprising that you’d expect to enter 2010 with flat to higher loan loss reserve as compared to this year. I wonder if you could just give more of an outlook in terms of why you expect to be heading into 2011 let’s say given the trends you have right now with the reserves.

If you look at the fourth quarter you can see that the provision as compared to the charge-offs was about $34 million or so over the charge-offs down substantially from where it’s been. If you look at each quarter throughout 2009 you would have seen charge-offs a little lighter in the first half of the year, heavier in the second half which is clearly reflective of how we’ve built the provision. I believe that given our outlook for charge-offs and I think we had the question earlier that we should probably continue to see first half provision continue to be in excess of charge-offs but at a declining rate. I believe that we’re very likely to see provision in the second half of the year be below charge-offs simply because I think we will continue to see improving credit metrics. I believe the broad base improvement we saw in the fourth quarter will largely continue throughout all of this year. Obviously we’ll look at it each quarter as we always do to see where we are if we’ve seen the kind of improvements we’ve seen in the fourth quarter we’ll adjust.

The economic recovery is not robust and so obviously that’ll be a factor that we’ll be keeping in mind as well.

There are no further questions at this time. I’ll turn the conference back over to management for any further remarks.

I want to thank everybody for being with us today and thank you for your continued interest in Comerica.

This does conclude today’s conference. Thank you for participating. You may now disconnect.