Comerica 2012 Annual Report Download - page 22

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12
require approval by the Strategic Credit Committee, chaired by Comerica's Chief Credit Officer and comprising senior credit,
market and risk management executives.
Commercial Loan Portfolio
Commercial loans are underwritten using a comprehensive analysis of the borrower's operations. The underwriting process
includes an analysis of some or all of the factors listed below:
• The borrower's business model.
• Periodic review of financial statements including financial statements audited by an independent certified public
accountant when appropriate.
• The pro-forma financial condition including financial projections.
• The borrower's sources and uses of funds.
• 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 (a type of credit score used to assess an applicant's credit risk) 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 generally 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, 2012, Comerica and its subsidiaries had 8,628 full-time and 678 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.