Comerica 2014 Annual Report Download - page 27

13
could cause actual results to differ materially from forward-looking statements, and future results could differ materially from
historical performance.
• General political, economic or industry conditions, either domestically or internationally, may be less favorable
than expected.
Local, domestic, and international economic, political and industry specific conditions affect the financial services
industry, directly and indirectly. Conditions such as or related to inflation, recession, unemployment, volatile interest
rates, international conflicts and other factors, such as real estate values, energy prices, state and local municipal budget
deficits, the recent European debt crisis and government spending and the U.S. national debt, outside of our control may,
directly and indirectly, adversely affect Comerica. As has been the case with the impact of recent economic conditions,
economic downturns could result in the delinquency of outstanding loans, which could have a material adverse impact
on Comerica's earnings.
• Governmental monetary and fiscal policies may adversely affect the financial services industry, and therefore
impact Comerica's financial condition and results of operations.
Monetary and fiscal policies of various governmental and regulatory agencies, in particular the FRB, affect the financial
services industry, directly and indirectly. The FRB regulates the supply of money and credit in the U.S. and its monetary
and fiscal policies determine in a large part Comerica's cost of funds for lending and investing and the return that can be
earned on such loans and investments. Changes in such policies, including changes in interest rates, will influence the
origination of loans, the value of investments, the generation of deposits and the rates received on loans and investment
securities and paid on deposits. Changes in monetary and fiscal policies are beyond Comerica's control and difficult to
predict. Comerica's financial condition and results of operations could be materially adversely impacted by changes in
governmental monetary and fiscal policies.
• Changes in regulation or oversight may have a material adverse impact on Comerica's operations.
Comerica is subject to extensive regulation, supervision and examination by the U.S. Treasury, the Texas Department of
Banking, the FDIC, the FRB, the SEC, FINRA and other regulatory bodies. Such regulation and supervision governs the
activities in which Comerica may engage. Regulatory authorities have extensive discretion in their supervisory and
enforcement activities, including the imposition of restrictions on Comerica's operations, investigations and limitations
related to Comerica's securities, the classification of Comerica's assets and determination of the level of Comerica's
allowance for loan losses. Any change in such regulation and oversight, whether in the form of regulatory policy,
regulations, legislation or supervisory action, may have a material adverse impact on Comerica's business, financial
condition or results of operations.
In particular, Congress and other regulators have significantly increased their focus on the regulation of the financial
services industry. Their actions include, but are not limited to, the passage of the Dodd-Frank Act, many parts of which
are now in effect, and the adoption of the Basel III framework in the U.S. For additional information on these actions,
please see “The Dodd-Frank Wall Street Reform and Consumer Protection Act and Other Recent Legislative and
Regulatory Developments” section of the “Supervisory and Regulation” section of this report. Many provisions in the
Dodd-Frank Act and the Basel III framework remain subject to regulatory rule-making and/or implementation, the effects
of which are not yet known.
Additionally, Comerica may be subject to other regulatory actions that are currently under consideration, or may be under
consideration in the future. For example, as discussed in the “The Dodd-Frank Wall Street Reform and Consumer
Protection Act and Other Recent Legislative and Regulatory Developments” section of the “Supervisory and Regulation”
section of this report, Comerica is not subject to the additional capital buffer for banking organizations deemed systemically
important to the global financial system. However, should U.S. banking regulators establish an additional capital buffer
for banking organizations deemed systemically important to the U.S. financial system, Comerica may be subject to an
additional buffer. Further, the current administration proposed in January 2010 a fee on those financial institutions that
benefited from recent actions taken by the U.S. government to stabilize the financial system. Calls for that fee were
renewed during the 2013 federal budget discussions. Most recently, the administration's 2015 budget proposal would
impose a 7 basis point tax on U.S. financial firms with assets over $50 billion, with the goal of such proposal to penalize
financial institutions for being overly leveraged. If such fee or another similar fee were implemented, Comerica would
likely be subject to its terms.
The effects of such legislation and regulatory actions on Comerica cannot reliably be fully determined at this time. We
can neither predict when or whether future regulatory or legislative reforms will be enacted nor what their contents will
be. The impact of any future legislation or regulatory actions on Comerica's businesses or operations cannot be reliably
determined at this time, and such impact may adversely affect Comerica.