Comerica 2011 Annual Report Download - page 22

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• The borrower’s debt service capacity.
• The guarantor’s financial strength.
• A comprehensive review of the quality and value of collateral, including independent third-party appraisals of
machinery and equipment and commercial real estate, as appropriate, to determine the advance rates.
• Physical inspection of collateral and audits of receivables, as appropriate.
Commercial Real Estate (CRE) Loan Portfolio
Comerica’s CRE loan portfolio consists of real estate construction and commercial mortgage loans and includes both
loans to real estate investors and developers, and loans secured by owner-occupied real estate. Comerica’s CRE loan
underwriting policies are consistent with the approach described above and provide maximum loan-to-value ratios that limit the
size of a loan to a maximum percentage of the value of the real estate collateral securing the loan. The loan-to-value percentage
varies by the type of collateral and is limited by advance rates established by our regulators. Our loan-to-value limitations are,
in certain cases, more restrictive than those required by regulators and are influenced by other risk factors such as the financial
strength of the borrower or guarantor, the equity provided to the project and the viability of the project itself. CRE loans
generally require cash equity. CRE loans are normally originated with full recourse or limited recourse to all principals and
owners. There are limitations to the size of a single project loan and to the aggregate dollar exposure to a single guarantor.
Consumer and Residential Mortgage Loan Portfolios
Comerica’s consumer and residential mortgage loans are originated consistent with the underwriting approach
described above, but also includes an assessment of each borrower’s personal financial condition, including a review of credit
reports and related FICO scores and verification of income and assets. Comerica does not originate subprime loan programs.
Although a standard industry definition for subprime loans (including subprime mortgage loans) does not exist, Comerica
defines subprime loans as specific product offerings for higher risk borrowers, including individuals with one or a combination
of high credit risk factors. These credit factors include low FICO scores, poor patterns of payment history, high debt-to-income
ratios and elevated loan-to-value. We consider subprime FICO scores to be those below 620 on a secured basis (excluding loans
with cash or near-cash collateral and adequate income to make payments) and below 660 for unsecured loans. Residential
mortgage loans retained in the portfolio are largely relationship based. The remaining loans are typically eligible to be sold on
the secondary market. Adjustable rate loans are limited to standard conventional loan programs.
EMPLOYEES
As of December 31, 2011, Comerica and its subsidiaries had 9,037 full-time and 720 part-time employees.
AVAILABLE INFORMATION
Comerica maintains an Internet website at www.comerica.com where the Annual Report on Form 10-K, Quarterly
Reports on Form 10-Q, Current Reports on Form 8-K and all amendments to those reports are available without charge, as soon
as reasonably practicable after those reports are filed with or furnished to the SEC. The Code of Business Conduct and Ethics
for Employees, the Code of Business Conduct and Ethics for Members of the Board of Directors and the Senior Financial
Officer Code of Ethics adopted by Comerica are also available on the Internet website and are available in print to any
shareholder who requests them. Such requests should be made in writing to the Corporate Secretary at Comerica Incorporated,
Comerica Bank Tower, 1717 Main Street, MC 6404, Dallas, Texas 75201.
Item 1A. Risk Factors.
This report includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. In
addition, Comerica may make other written and oral communications from time to time that contain such statements. All
statements regarding Comerica’s expected financial position, strategies and growth prospects and general economic conditions
Comerica expects to exist in the future are forward-looking statements. The words, “anticipates,” “believes,” “feels,” “expects,”
“estimates,” “seeks,” “strives,” “plans,” “intends,” “outlook,” “forecast,” “position,” “target,” “mission,” “assume,”
“achievable,” “potential,” “strategy,” “goal,” “aspiration,” "opportunity," "initiative," “outcome,” “continue,” “remain,”
“maintain,” "on course," “trend,” “objective,” "looks forward" and variations of such words and similar expressions, or future
or conditional verbs such as “will,” “would,” “should,” “could,” “might,” “can,” “may” or similar expressions, as they relate to
Comerica or its management, are intended to identify forward-looking statements.