Comerica 2012 Annual Report Download - page 12

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We provide financial information for our segments and information about our non-U.S. revenues and long-lived assets:
(1) under the caption, "Strategic Lines of Business" on pages F-13 through F-16 of the Financial Section of this report; and (2) in
Note 22 of the Notes to Consolidated Financial Statements located on pages F-108 through F-112 of the Financial Section of this
report.
We provide information about the net interest income and noninterest income we received from our various classes of
products and services: (1) under the caption, "Analysis of Net Interest Income-Fully Taxable Equivalent (FTE)" on page F-6 of
the Financial Section of this report; (2) under the caption "Net Interest Income" on pages F-7 through F-8 of the Financial Section
of this report; and (3) under the caption "Noninterest Income" on pages F-9 through F-10 of the Financial Section of this report.
We provide information on risks attendant to foreign operations: (1) under the caption "Concentration of Credit Risk"
on page F-31 of the Financial Section of this report; and (2) under the caption "International Exposure" on page F-35 of the
Financial Section of this report.
COMPETITION
The financial services business is highly competitive. Comerica and its subsidiaries mainly compete in their three primary
geographic markets of Texas, California and Michigan, as well as in the states of Arizona and Florida. They also compete in
broader, national geographic markets, as well as markets in Mexico and Canada. They are subject to competition with respect to
various products and services, including, without limitation, loans and lines of credit, deposits, cash management, capital market
products, international trade finance, letters of credit, foreign exchange management services, loan syndication services, fiduciary
services, private banking, retirement services, investment management and advisory services, investment banking services,
brokerage services, the sale of annuity products, and the sale of life, disability and long-term care insurance products.
Comerica believes that the level of competition in all geographic markets will continue to increase in the future. In
addition to banks, Comerica's banking subsidiaries also face competition from other financial intermediaries, including savings
and loan associations, consumer finance companies, leasing companies, venture capital funds, credit unions, investment banks,
insurance companies and securities firms. Competition among providers of financial products and services continues to increase,
with consumers having the opportunity to select from a growing variety of traditional and nontraditional alternatives. The ability
of non-banking financial institutions to provide services previously limited to commercial banks has intensified competition.
Because non-banking financial institutions are not subject to many of the same regulatory restrictions as banks and bank holding
companies, they can often operate with greater flexibility and lower cost structures. In addition, the industry continues to consolidate,
which affects competition by eliminating some regional and local institutions, while strengthening the franchises of acquirers.
SUPERVISION AND REGULATION
Banks, bank holding companies and financial institutions are highly regulated at both the state and federal level. Comerica
is subject to supervision and regulation at the federal level by the Board of Governors of the Federal Reserve System ("FRB")
under the Bank Holding Company Act of 1956, as amended. The Gramm-Leach-Bliley Act expanded the activities in which a
bank holding company registered as a financial holding company can engage. The conditions to be a financial holding company
include, among others, the requirement that each depository institution subsidiary of the holding company be well capitalized and
well managed. Effective July 2011, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Financial Reform
Act") also requires the well capitalized and well managed standards to be met at the financial holding company level. Comerica
became a financial holding company in 2000. As a financial holding company, Comerica may affiliate with securities firms and
insurance companies and engage in activities that are financial in nature. Activities that are "financial in nature" include, but are
not limited to: securities underwriting; securities dealing and market making; sponsoring mutual funds and investment companies
(subject to the prohibitions of the Volcker Rule, once implemented through regulation, described below); insurance underwriting
and agency; merchant banking; travel agent services; and activities that the FRB has determined to be financial in nature or
incidental or complementary to a financial activity, provided that it does not pose a substantial risk to the safety or soundness of
the depository institution or the financial system generally. A bank holding company that is not also a financial holding company
is limited to engaging in banking and other activities previously determined by the FRB to be closely related to banking.
Comerica 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. Comerica Bank has elected to be a member of the Federal Reserve System ("FRS")
under the Federal Reserve Act and, consequently, is supervised and regulated by the Federal Reserve Bank of Dallas. Comerica
Bank & Trust, National Association is chartered under federal law and is subject to supervision and regulation by the Office of
the Comptroller of the Currency ("OCC") under the National Bank Act. Comerica Bank & Trust, National Association, by virtue
of being a national bank, is also a member of the FRS. The deposits of Comerica Bank and Comerica Bank & Trust, National
Association are insured by the Deposit Insurance Fund ("DIF") of the Federal Deposit Insurance Corporation ("FDIC") to the
extent provided by law.
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