EXHIBIT 99.2

STATEMENT UNDER OATH OF PRINCIPAL FINANCIAL OFFICER REGARDING FACTS AND
CIRCUMSTANCES RELATING TO EXCHANGE ACT FILINGS

I, Elizabeth S. Acton, state and attest that:

(1)      To the best of my knowledge, based upon a review of the covered reports
         of Comerica Incorporated, and, except as corrected or supplemented in a
         subsequent covered report:

         -        no covered report contained an untrue statement of a material
                  fact as of the end of the period covered by such report (or in
                  the case of a report on Form 8-K or definitive proxy
                  materials, as of the date on which it was filed); and

         -        no covered report omitted to state a material fact necessary
                  to make the statements in the covered report, in light of the
                  circumstances under which they were made, not misleading as of
                  the end of the period covered by such report (or in the case
                  of a report on Form 8-K or definitive proxy materials, as of
                  the date on which it was filed).

(2)      I have reviewed the contents of this statement with the Audit and Legal
         Committee of the Board of Directors of Comerica Incorporated.

(3)      In this statement under oath, each of the following, if filed on or
         before the date of this statement, is a "covered report":

         -        Annual Report on Form 10-K for the Fiscal Year Ended December
                  31, 2001 of Comerica Incorporated;

         -        all reports on Form 10-Q, all reports on Form 8-K and all
                  definitive proxy materials of Comerica Incorporated filed with
                  the Commission subsequent to the filing of the Form 10-K
                  identified above; and

         -        any amendments to any of the foregoing.



/s/ Elizabeth S. Acton                     Subscribed and sworn to
- -------------------------------            before me this 13th day of
Elizabeth S. Acton                         August 2002.
August 13, 2002
                                           /s/ Mary Lou Chorazyczewski
                                           -----------------------------------
                                           Notary Public

                                           My Commission Expires:

                                           -----------------------------------
                                           MARY LOU CHORAZYCZEWSKI
                                           NOTARY PUBLIC OAKLAND CO., MI
                                           MY COMMISSION EXPIRES Oct 5, 2003
                                           acting in Wayne County