Comerica Incorporated (‘Comerica’) operates as a financial services company.
As of December 31, 2024, the company owned directly or indirectly all the outstanding common stock of two active banking subsidiaries (Comerica Bank, a Texas banking association, and Comerica Bank & Trust, National Association), as well as non-banking subsidiaries.
Segments
Comerica has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank, and Wealth Management...
Comerica Incorporated (‘Comerica’) operates as a financial services company.
As of December 31, 2024, the company owned directly or indirectly all the outstanding common stock of two active banking subsidiaries (Comerica Bank, a Texas banking association, and Comerica Bank & Trust, National Association), as well as non-banking subsidiaries.
Segments
Comerica has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank, and Wealth Management. The company operates in five primary geographic markets - Texas, California, Michigan, Arizona, and Florida - and secondarily in several mountain, southeastern, and other states, as well as in Canada and Mexico.
The Commercial Bank (the ‘Bank’) meets the needs of small and middle-market businesses, multinational corporations, and governmental entities by offering various products and services, including commercial loans and lines of credit, deposits, cash management, payment solutions, card services, capital market products, international trade finance, and letters of credit.
The Retail Bank includes a full range of personal financial services, consisting of consumer lending, consumer deposit gathering, and mortgage loan origination. This business segment offers a variety of consumer products, including deposit accounts, installment loans, credit cards, home equity lines of credit, and residential mortgage loans. In addition, this business segment offers products and services to small businesses that are serviced through a team of dedicated small business bankers and the company’s branch network.
Wealth Management provides products and services to affluent, high-net-worth, and ultra-high-net-worth individuals and families, business owners, and executives, as well as institutional clients, including comprehensive financial planning, trust and fiduciary services, investment management and advisory, brokerage, private banking, and business transition planning services.
The Finance category includes the Corporation’s securities portfolio and asset and liability management activities. Finance is responsible for managing the Corporation’s funding, liquidity, and capital needs, performing interest sensitivity analysis, and executing various strategies to manage the Corporation’s exposure to liquidity, interest rate risk, and foreign exchange risk.
Commercial Real Estate (CRE) Loan Portfolio
Comerica's CRE loan portfolio consists of real estate construction and commercial mortgage loans and includes loans to real estate developers and investors, as well as loans secured by owner-occupied real estate.
Deposits
As of December 31, 2024, the company’s deposits included noninterest-bearing deposits, money market and interest-bearing checking deposits, savings deposits, customer certificates of deposit, other time deposits, and foreign office time deposits.
Investment Securities
As of December 31, 2024, the company’s investment portfolio included U.S. Treasury securities, residential mortgage-backed securities, and commercial mortgage-backed securities.
Supervision And Regulation
Comerica is subject to supervision and regulation at the federal level by the Board of Governors of the Federal Reserve System through the Federal Reserve Bank of Dallas, pursuant to the Bank Holding Company Act of 1956, as amended.
Comerica Bank (the ‘Bank’) is chartered by the State of Texas and, at the state level, is supervised and regulated by the Texas Department of Banking under the Texas Finance Code and the Texas Administrative Code. The Bank has elected to be a member of the Federal Reserve System under the Federal Reserve Act and, consequently, is supervised and regulated by the Federal Reserve Bank (‘FRB’). Comerica Bank & Trust, National Association is federally chartered and is subject to supervision and regulation by the Office of the Comptroller of the Currency (‘OCC’), pursuant to the National Bank Act. Comerica Bank & Trust, National Association, by virtue of being a national bank, is also a member of the Federal Reserve System. Furthermore, given that the Bank is a bank with assets in excess of $10 billion, it is subject to supervision and regulation by the Consumer Financial Protection Bureau (‘CFPB’) for purposes of assessing compliance with federal consumer financial laws. The Bank's deposits, and those of Comerica Bank & Trust, National Association, are insured by the Deposit Insurance Fund (‘DIF’) of the Federal Deposit Insurance Corporation (‘FDIC’) to the fullest extent provided by law, and therefore the Bank and Comerica Bank & Trust, National Association are each also subject to regulation by the FDIC. Certain transactions executed by the Bank are also subject to regulation by the U.S. Commodity Futures Trading Commission (‘CFTC’). The Department of Labor (‘DOL’) regulates financial institutions providing services to plans governed by the Employee Retirement Income Security Act of 1974. The Bank’s Canada branch is supervised by the Office of the Superintendent of Financial Institutions, and its Mexico representative office is also supervised by the Banco de México. The Bank is also registered in the Cayman Islands and is subject to supervision by the Cayman Islands Monetary Authority.
The FRB supervises non-banking activities conducted by companies directly and indirectly owned by Comerica. In addition, Comerica’s non-banking subsidiaries are subject to supervision and regulation by various state, federal, and self-regulatory agencies, including, but not limited to, the Financial Industry Regulatory Authority, Inc. (‘FINRA’), the Department of Licensing and Regulatory Affairs of the State of Michigan, and the Securities and Exchange Commission (‘SEC’) (in the case of Comerica Securities, Inc.); and the Department of Insurance and Financial Services of the State of Michigan (in the case of Comerica Insurance Services, Inc.).
The Community Reinvestment Act of 1977 (‘CRA’) requires U.S. banks to help serve the credit needs of their communities. Comerica's current CRA rating is ‘Outstanding.’
Comerica is also subject to the disclosure and regulatory requirements of the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended (the ‘Exchange Act’), both as administered by the SEC, as well as the rules of the New York Stock Exchange.
Acquisitions of Comerica’s voting stock above certain thresholds are subject to prior regulatory notice or approval under federal banking laws, including the Bank Holding Company Act of 1956 and the Change in Bank Control Act of 1978.
Comerica and its bank subsidiaries are subject to risk-based capital requirements and guidelines imposed by the FRB, FDIC, and/or the OCC.
Comerica's loan operations are subject to federal laws and implementing regulations applicable to credit transactions, such as the Truth-In-Lending Act, the Home Mortgage Disclosure Act of 1975, the Equal Credit Opportunity Act, the Fair Credit Reporting Act of 1978 (‘FCRA’), the Fair Debt Collection Practices Act, the Servicemembers Civil Relief Act, the Dodd-Frank Act, and rules and regulations of the various federal agencies charged with the responsibility of implementing these federal laws. State usury laws and federal laws concerning interest rates apply to interest and other charges collected or contracted for by Comerica.
Comerica's deposit operations are subject to multiple federal laws, including the Right to Financial Privacy Act, the Truth in Savings Act, and the Electronic Funds Transfer Act. The Dodd-Frank Act amended the Electronic Funds Transfer Act to, among other things, give the Federal Reserve Board the authority to establish rules regarding interchange fees charged for electronic debit transactions by payment card issuers having assets over $10 billion and to enforce a new statutory requirement that such fees be reasonable and proportional to the actual cost of a transaction to the issuer.
Comerica is subject to many U.S. federal, U.S. state, and international laws and regulations governing consumer data privacy protection, which require, among other things, maintaining policies and procedures to protect the non-public confidential information of customers and employees. The privacy provisions of the Gramm-Leach-Bliley Act generally prohibit financial institutions from disclosing nonpublic personal financial information of consumer customers to third parties for certain purposes (primarily marketing), unless customers have the opportunity to ‘opt out’ of the disclosure.
Comerica has a physical footprint in California and is required to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act in 2023 (collectively, the ‘CCPA’). The company’s subsidiary banks are subject to FDIC deposit insurance assessments to maintain the DIF.
Comerica is subject to several federal laws that are designed to combat money laundering, terrorist financing, and transactions with persons, companies, or foreign governments designated by U.S. authorities (‘AML laws’). This category of laws includes the Currency and Foreign Transaction Reporting Act of 1970, as amended (the ‘Bank Secrecy Act’), the Money Laundering Control Act, and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, or USA PATRIOT Act.
Comerica is subject to guidance issued by the FRB, OCC, and FDIC intended to ensure that the incentive compensation policies of banking organizations do not undermine the safety and soundness of such organizations by encouraging excessive risk-taking.
Comerica is subject to regulation by the CFPB, which has broad rule-making authority for a wide range of consumer protection laws that apply to all banks and savings institutions and possesses examination and enforcement authority over all banks and savings institutions with more than $10 billion in assets, including the Bank, and their depository affiliates.
Comerica is also subject to certain state consumer protection laws, and under the Dodd-Frank Act, state attorneys general and other state officials are empowered to enforce certain federal consumer protection laws and regulations.
History
The company was founded in 1849. The company was incorporated in 1972 under the laws of the state of Delaware. The company was formerly known as DETROITBANK Corporation and changed its name to Comerica Incorporated in July 1982.