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EXHIBIT 99.2
Comerica Tower at Detroit Center
Corporate Legal Department
500 Woodward Avenue, 33rd Floor
Detroit, Michigan 48226
(313) 222-7464
(313) 222-9480 - Facsimile
Julius L. Loeser
Senior Vice President and
Deputy General Counsel
VIA FACSIMILE (312)-913-2479
& VIA AIRBORNE EXPRESS
November 28, 2000
Jack Wixted, Senior Vice President
Federal Reserve Bank of Chicago
230 South LaSalle Street
Chicago, IL 60604-1413
Re: Declaration of Election to be Financial Holding Company
Dear Mr. Wixted:
We are filing on behalf of Comerica Holdings Incorporated, currently a
bank holding company, pursuant to Section 4(l)(i) of the Bank Holding Company
Act (12 U.S.C.ss.1843 (l)(i)) and Section 225.82 of the Board's Regulation Y,
this written declaration of its election to become a financial holding company.
1. Statement Election
Comerica Holdings Incorporated elects to be a financial holding
company.
2. Company and Each Depository Institution Subsidiary
The name of the company is Comerica Holdings Incorporated. The address
of its head office is 500 Woodward Avenue, Detroit, Michigan 48226.
The name and address of each depository institution subsidiary is:
a.) Comerica Bank-California
333 W. Santa Clara Street
San Jose, California 95113
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Jack Wixted, Senior Vice President
Federal Reserve Bank of Chicago
November 28, 2000
Page 2
b.) Comerica Bank-Texas
Thanksgiving Tower
1601 Elm Street
Dallas, Texas 72201
3. Capitalization
I hereby certify that all depository institutions controlled by the
company are well capitalized as of this date.
4. Capital Ratios
The capital ratios for all relevant capital measures as of the close of
the previous quarter for each depository institution controlled by the company
on this date are set forth in the attachment to this letter.
5. Management
The undersigned hereby certifies that all depository institutions
controlled by the company are "well-managed", as of the date of this letter.
Thank you for your consideration of this declaration. If you have any
questions about what we propose, we would be pleased to answer them.
Best wishes,
/s/ Julius L. Loeser
cc: Mitchell Doepke
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Jack Wixted, Senior Vice President
Federal Reserve Bank of Chicago
November 28, 2000
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bcc: Ralph Babb
Marvin Elenbaas
Michael Fidler
John Gonzalez
George Madison
Ronald Marks
Michael Michalak
Eugene Miller
Jay Oberg
Thomas Ogden
Mark Yonkman
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Summary of Risk-Based Capital
and Leverage Ratios
September 30, 2000
Tier 1 Tier 2 Risk-adj. Adj. Total Leverage Tier I Total
Capital Capital Assets Assets (i) Ratio (2) Ratio Ratio
------- ------- --------- ---------- --------- ------ -----
Comerica Bank - Texas 401,711 148,045 3,815,643 3,758,472 10.69% 10.53% 14.41%
Comerica Bank - California 457,543 207,538 6,198,916 5,134,600 8.91% 7.38% 10.73%
(1) Adjusted total assets are defined as the quarterly average total assets
reported on the FRY-9C or the call report, less goodwill and other
intangibles acquired after February, 1992.
(2) Tier 1 capital divided by adjusted total assets.