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Letter to Shareholders
Growth

We have an established retail distribution system in Michigan and continue to enjoy a leadership position in the state as the business bank of choice among companies of all sizes. Our brand recognition in the market continues to be very high, and was greatly enhanced in 2006 when several post-season baseball games were played at Comerica Park, home of the American League Champion Detroit Tigers. Because of our relationships and strong local knowledge, we believe we can continue to generate good business in Michigan, even in the face of a slow state economy.

We are exporting our relationship banking expertise, nurtured for more than 150 years in Michigan, to this country’s most attractive and fastest-growing markets: California, Texas, Arizona and Florida. This is helping us to diversify our earnings mix, so we are far less dependent on any one market or business segment. Our plan is to continue to grow our presence in these high-growth markets.

Today, Comerica operates in seven of the eleven largest cities in the United States – Los Angeles, Houston, Phoenix, San Diego, Dallas, San Jose and Detroit.

The U.S. Census Bureau projects that three states – California, Texas and Florida – should account for nearly one-half of total U.S. population growth between 2000 and 2030. Each of the three states is expected to gain more than 12 million people between 2000 and 2030. Arizona, in terms of population, is expected to rise from 20th place in 2000 to 10th place in 2030.

Such projections help fuel our belief that the best opportunities for future growth of Comerica lie in these fastest-growing markets.

Opening new banking centers in these fastest-growing markets is an important part of our growth strategy. Unlike other banks, our intention is not to blanket every market with branches. Rather, we are much more selective. We are opening banking centers in key markets where we can grow business banking, small business, wealth management and retail all at once.

Since our initial three-year banking center expansion program began in late 2004, we’ve opened 60 new banking centers, up from our original target of 50. In 2006, we opened 25 new banking centers. We also refurbished 19 banking centers and relocated seven others to more visible and convenient locations.

Among the new banking centers opened since 2004, we’re seeing a nicely balanced distribution of loans and deposits from each of our business segments. This is important as we look for sites that provide a balance of middle market, small business and affluent households. By engaging all of our lines of business, we greatly improve the rate of success for the new banking centers. We have obtained almost $800 million in deposits from our new banking centers since beginning the expansion program in late 2004.

Our goal is to have our new banking centers become profitable within 18 months. Our expansion program is meeting that target. As we expand our banking centers, we closely manage our human capital and expenses.

We are currently planning to open about 30 banking centers in 2007.