United States securities and exchange commission logo
October 4, 2023
James Herzog
Senior Executive Vice President and Chief Financial Officer
Comerica Inc.
Comerica Bank Tower
1717 Main Street, MC 6404
Dallas, Texas 75201
Re: Comerica Inc.
Form 10-Q for the
Quarterly Period Ended June 30, 2023
Filed July 26, 2023
File No. 001-10706
Dear James Herzog:
We have conducted a limited review of your quarterly report and
have the following
comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-Q for the Quarterly Period Ended June 30, 2023
Supplemental Financial Data, page 61
1. We note your
presentation of the Non-GAAP measures tangible common equity,
excluding AOCI,
tangible common equity ratio, excluding AOCI, and tangible equity per
share of common stock,
excluding AOCI. Further, we note your disclosure that the
measures provide a
greater understanding of ongoing operations and enhances
comparability with
prior periods. Please address the following:
Tell us and revise
your disclosures, in future filings, to more fully explain what these
measures represent
and how they provide a greater understanding of ongoing
operations.
Tell us how you
determined the adjustment to exclude accumulated other
comprehensive
income (loss) is appropriate, including your consideration of whether
the adjustment
relates to normal, recurring activities of the Company or if it results in
individually
tailored accounting. Refer to Question 100.04 of the Division of
James Herzog
Comerica Inc.
October 4, 2023
Page 2
Corporation Finance s Compliance & Disclosure Interpretations
on Non-GAAP
Financial Measures.
Tell us whether you will continue to present these measures and
adjustments during
periods where there is an accumulated other comprehensive gain
rather than a loss,
which would result in a reduction to these non-GAAP measures
excluding AOCI.
Refer to Question 100.03 of the Division of Corporation Finance
s Compliance
& Disclosure Interpretations on Non-GAAP Financial Measures.
Tell us how you concluded it was appropriate to not also add
back the impact of
AOCI to the denominator (total tangible assets) so that both the
numerator and
denominator would be calculated on a consistent basis.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact William Schroeder at 202-551-3294 or Ben Phippen at
202-551-3697 with
any questions.
FirstName LastNameJames Herzog Sincerely,
Comapany NameComerica Inc.
Division of
Corporation Finance
October 4, 2023 Page 2 Office of Finance
FirstName LastName