Comerica Incorporated : 1Q24 Regulatory Capital Disclosures

COMERICA INCORPORATED

REGULATORY CAPITAL DISCLOSURES

For the Quarter Ended March 31, 2024

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Table of Contents

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Scope of Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Capital Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Capital Adequacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Risk Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Credit Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Counterparty Credit Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Credit Risk Mitigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Equities Not Subject to Market Risk Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Market Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Interest Rate Risk for Non-TradingActivities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Forward-LookingStatements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Disclosure Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix A

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OVERVIEW

Organization

Comerica Incorporated ("Comerica") is a financial services company, incorporated under the laws of the State of Delaware, and headquartered in Dallas, Texas. Comerica has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank, and Wealth Management. Comerica operates in five primary geographic markets - Texas, California, Michigan, Arizona and Florida - and secondarily in several mountain, southeastern, and other states, and in Canada and Mexico. Comerica operates two U.S. banking subsidiaries: Comerica Bank, a Texas banking association, and Comerica Bank & Trust, National Association, a limited purpose trust bank. At March 31, 2024, Comerica had total assets of approximately $79.4 billion, total deposits of approximately $63.6 billion, total loans of approximately $50.8 billion and shareholders' equity of approximately $6.1 billion.

Regulatory Capital Standards and Disclosures

Comerica and its U.S. banking subsidiaries are subject to various regulatory capital requirements administered by federal and state banking agencies under the Basel III(1) regulatory framework (Basel III). This regulatory framework establishes comprehensive methodologies for calculating regulatory capital and risk-weighted assets (RWA). Basel III also set minimum capital ratios as well as overall capital adequacy standards.

Definition of capital

Under Basel III, regulatory capital comprises Common Equity Tier 1 (CET1) capital, additional Tier 1 capital and Tier 2 capital. CET1 capital predominantly includes common shareholders' equity, less certain deductions for goodwill, intangible assets and deferred tax assets that arise from net operating losses and tax credit carry-forwards. Additionally, Comerica has elected to permanently exclude capital in accumulated other comprehensive income (AOCI) related to debt and equity securities classified as available-for-sale as well as for cash flow hedges and defined benefit postretirement plans from CET1, an option available to standardized approach entities under Basel III. Tier 1 capital incrementally includes noncumulative perpetual preferred stock. Tier 2 capital includes Tier 1 capital as well as subordinated debt qualifying as Tier 2 and qualifying allowance for credit losses.

Risk-weighted assets

Comerica computes RWA using the standardized approach. Under the standardized approach, RWA is generally based on supervisory risk-weightings which vary by counterparty type and asset class. Under the Basel III standardized approach, capital is required for credit risk RWA to cover the risk of unexpected losses due to failure of a customer or counterparty to meet its financial obligations in accordance with contractual terms. If trading assets and liabilities exceed certain thresholds, an entity is also subject to the market risk provisions of Basel III ("market risk rule") and capital is also required for market risk RWA to cover the risk of losses due to adverse market movements or from position-specific factors.

Disclosures

The qualitative and quantitative disclosures in this report regarding Comerica's capital structure, capital adequacy, risk exposures, RWA and market risk (if applicable) are based on management's current understanding of Basel III and other factors, which may be subject to change as additional clarification and implementation guidance is received from regulators and the interpretation of the rule evolves over time. The disclosures were reviewed and approved in accordance with Comerica's regulatory disclosure policy, which has been approved by Comerica's Board of Directors.

This report should be read in conjunction with Comerica's Annual Report on Form 10-K for the year ended December 31, 2023 ("2023 Form 10-K"), and Quarterly Report on Form 10-Q for the period ended March 31, 2024 ("First quarter 2023 Form 10-

1. which includes important information on risk management policies and practices. A disclosure index is provided in Appendix A of this report and specific references have been included herein.

(1)The final U.S. Basel III rules applicable to Comerica and Comerica Bank are codified in 12 C.F.R. Part 217 (Federal Reserve Board).

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SCOPE OF APPLICATION

Basis of consolidation

The standardized approach to risk-weighted assets under Basel III applies to Comerica's consolidated financial statements and off-balance sheet exposures. Comerica's basis of consolidation for both financial and regulatory reporting purposes is in accordance with U.S. Generally Accepted Accounting Principles ("GAAP"). Certain of Comerica's equity investments accounted for under either the proportional method, equity method or cost method are neither consolidated nor deducted from regulatory capital under Basel III, but instead are assigned an appropriate risk weight. There are no entities within Comerica enterprise that are deconsolidated or whose capital is deducted for Basel III.

• For further information regarding Comerica's principles of consolidation, see Note 1 to the consolidated financial statements on page F-47 of Comerica's 2023 Form 10-K.

Capital in regulated subsidiaries

At March 31, 2024, total capital for each of Comerica's regulated banking subsidiaries, Comerica Bank and Comerica Bank & Trust, National Association, exceeded their respective minimum required regulatory capital amount. Comerica's regulated broker-dealer subsidiary, Comerica Securities, Inc., was also in compliance with minimum net capital requirements at March 31, 2024.

Restrictions on funds and capital transfers

Various federal laws limit borrowings by Comerica and its nonbank subsidiaries from its affiliate insured banking subsidiaries, and also limit various other transactions between Comerica and its nonbank subsidiaries, on the one hand, and Comerica's affiliate insured banking subsidiaries, on the other.

• Refer to "Transactions with Affiliates" in Part I, Item 1 on page 6 of Comerica's 2023 Form 10-K for further information.

There are statutory and regulatory requirements restricting the payment of dividends by subsidiary banks to Comerica, as well as by Comerica to its shareholders.

• For further information, see "Dividends" on page 5 in Part I, Item 1 and Note 20 to the consolidated financial statements on page F-93 to F-94 of Comerica's 2023 Form 10-K.

Shares of common stock can only be redeemed by Comerica through repurchases.

• For additional information about capital and Comerica's share repurchase program, see "Capital" in Part I, Item 2 on page 46 of Comerica's First Quarter 2024 Form 10-Q.

CAPITAL STRUCTURE

Regulatory capital instruments

Comerica's currently qualifying regulatory capital instruments consist of common stock, preferred stock and subordinated debt. Each share of Comerica's common stock entitles the holder to one vote for the election of directors and for all other matters to be voted on by Comerica's shareholders. Upon a liquidation, dissolution or similar proceeding, the holders of common stock would share proportionally in the residual assets remaining after all claims have been satisfied. Shares of common stock can only be redeemed by Comerica through repurchases.

Each depositary share of Comericas's preferred stock entitles the holder to proportional rights and preferences (including dividend, voting, redemption and liquidation rights). The terms of the preferred stock have been established to satisfy the criteria for "additional Tier 1 capital" instruments consistent with Basel III as set forth in the joint final rulemaking issued in July 2013 by the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency.

• For additional information about capital and Comerica's share repurchase program, see "Capital" in Part I, Item 2 on page 46 of Comerica's First Quarter 2024 Form 10-Q.
• For additional information about the terms of the preferred stock and depositary shares, see Note 13 to the consolidated financial statements on page F-82 of Comerica's 2023 Form 10-K, as well as the Form 8-K filed by Comerica on May 26, 2020 and Exhibits 3.1 and 4.1 thereto.

Comerica's subordinated debt contains no financial covenants. The subordinated debt is subject to standard events of default, including those related to payment of principal and interest, bankruptcy, insolvency, receivership and other similar actions and compliance with typical legal covenants.

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• For further details regarding subordinated debt as of March 31, 2024, see Note 7 to the consolidated financial statements on page 24 of Comerica's First Quarter 2024 Form 10-Q.

Regulatory capital components

Table 1: Reconciliation of Shareholders' Equity to Total Capital

A reconciliation of total shareholders' equity to CET1 capital, Tier 1 capital and Total capital is presented below.

(in millions)		March 31, 2024
Preferred stock	$	394
Common stock		1,141
Capital surplus		2,202
Accumulated other comprehensive loss		(3,457)
Retained earnings		11,765
Less cost of common stock in treasury		(5,995)
Total shareholders' equity before adjustments and deductions		6,050
Less: Preferred stock		394
Total Common stockholders' equity		5,656
Less adjustments and deductions:
AOCI opt-out election related adjustments		(3,457)
Goodwill		635
Other adjustments and deductions		9
Total CET1 capital		8,469
Add: Preferred stock		394
Total Tier 1 capital		8,863
Qualifying subordinated debt		727
Allowance for credit losses includable in Tier 2 capital		728
Tier 2 capital		1,455
Total capital	$	10,318

Further details about Comerica's regulatory capital can be found in Schedule HC-R to the March 31, 2024 Consolidated Financial Statements for Holding Companies - Form FR Y-9C.

CAPITAL ADEQUACY

Capital adequacy assessment process

Comerica assesses capital adequacy against the risk inherent in the balance sheet, recognizing that unexpected loss is the common denominator of risk and that common equity has the greatest capacity to absorb unexpected loss. Comerica periodically conducts stress tests to evaluate potential impacts to Comerica's forecasted financial condition under various economic scenarios and business conditions. These stress tests are a normal part of Comerica's overall risk management and capital planning process and are part of the forecasting process used by Comerica to conduct enterprise-wide stress tests.

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Risk-weighted assets

Table 2: Risk-Weighted Assets by Exposure Type

The following table presents components of Comerica's risk-weighted assets calculated in accordance with the Basel III standardized approach as of March 31, 2024.

(in millions)		March 31, 2024
Cash items in process of collection	$	82
Exposures conditionally guaranteed by U.S. government agencies		67
Claims on U.S. government-sponsored entities		2,163
Exposures to state and local governments in the U.S.		9
Claims on and exposures guaranteed by U.S. depository institutions and foreign banks		85
Corporate exposures		45,815
High volatility commercial real estate loans		481
Residential mortgage loans1		2,847
Consumer loans		449
Past due loans		339
Equity exposures		1,796
Other assets		4,438
Off-balance sheet commitments with original maturity greater than 1 year		11,422
Off-balance sheet commitments with original maturity of 1 year or less		602
Other off-balance sheet exposures		2,051
Over-the-counter derivative contracts		1,027
Standardized market risk-weighted assets		121
Total standardized risk-weighted assets	$	73,794

• Loans collateralized by one-to-four family residential properties, including consumer home equity loans.
• • Further details about Comerica's risk-weighted assets can be found in Schedule HC-R to the March 31, 2024 Consolidated Financial Statements for Holding Companies - Form FR Y-9C.

Risk-based capital ratios

Comerica and its U.S. banking subsidiaries are required to maintain minimum ratios of CET1, Tier 1 and Total capital to risk- weighted assets, as well as minimum leverage ratios (defined as Tier 1 capital divided by adjusted average assets) to be considered "adequately capitalized." Failure to meet minimum capital requirements could initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a direct material effect on Comerica's financial condition and results of operations.

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Table 3: Minimum Required Capital Ratios

The following table presents the minimum ratios that Comerica and its U.S. banking subsidiaries are subject to as of March 31, 2024.

		Well Capitalized Ratios for
March 31, 2024	Minimum Capital Ratios	Bank Holding Companies (a)

CET1 capital to risk-weighted assets Tier 1 capital to risk-weighted assets Total capital to risk-weighted assets

Tier 1 capital to adjusted average assets (leverage ratio)

7.0 % (b)	- %
8.5	(b)	6.0
10.5	(b)	10.0
4.0		-

1. The requirements for Comerica's bank subsidiaries to be considered "well capitalized" are 6.5% for CET1 capital, 8.0% for Tier 1 capital, 10.0% for total capital and a leverage ratio of at least 5.0%.
2. In addition to the minimum risk-based capital requirements, Comerica is required to maintain a minimum capital conservation buffer of 2.5%, in the form of common equity, in order to avoid restrictions on capital distributions and discretionary bonuses.

Table 4: Summary of Capital Positions and Ratios

The following table presents a summary of the capital positions of Comerica, Comerica Bank and Comerica Bank & Trust, National Association under the Basel III standardized approach at March 31, 2024.

March 31, 2024					Comerica Bank &
					Trust, National
(dollar amounts in millions)		Comerica		Comerica Bank
			Association
CET1 capital	$	8,469	$	8,157	$	95
Tier 1 capital		8,863		8,157		95
Total capital		10,318		9,512		95
Eligible retained income (a)	$	304	$	176	$	24
Risk-weighted assets	$	73,794	$	73,712	$	41
Adjusted average assets (b)		86,599		86,367		97
CET1 capital to risk-weighted assets		11.48 %		11.07 %		233.91 %
Tier 1 capital to risk-weighted assets		12.01		11.07		233.91
Total capital to risk-weighted assets		13.98		12.90		233.91
Capital conservation buffer (c)		5.98		4.90		225.91
Tier 1 capital to adjusted average assets (leverage ratio)		10.23		9.44		97.78

1. Represents the amount to which restrictions on capital distributions and discretionary bonuses would apply if the capital conservation buffer falls below the required minimum. Eligible retained income is the greater of the sum of net income for the four preceding calendar quarters, net of any distributions not already reflected in net income (e.g., dividend payments and share repurchases) and the average net income over the four preceding calendar quarters.
2. Adjusted average assets include total quarterly average assets (reflecting available-for-sale securities at amortized cost), less amounts deducted from CET1 capital and additional Tier 1 capital, plus assets derecognized as an adjustment to AOCI as part of the incremental effect of applying certain provisions in accounting for defined benefit postretirement plans.
3. Comerica and its U.S. bank subsidiaries are required to maintain a capital conservation buffer of 2.5% in order to avoid restrictions on capital distributions and discretionary bonuses. The capital conservation buffer is the lowest of (i) CET1 ratio less minimum CET1 requirement, (ii) Tier 1 ratio less minimum Tier 1 requirement and (iii) Total capital ratio less minimum Total capital requirement.

At March 31, 2024, Comerica and its U.S. banking subsidiaries exceeded the ratios required for an institution to be considered "well capitalized." There have been no events since March 31, 2024 that management believes have changed the capital adequacy classification of Comerica or its U.S. banking subsidiaries.

RISK MANAGEMENT

As a result of conducting business in the normal course, Comerica assumes various types of risk. Comerica's enterprise risk framework provides a process for identifying, measuring, controlling and managing these risks. This framework incorporates a risk assessment process, a collection of risk committees that manage Comerica's major risk elements, and a risk appetite statement that outlines the levels and types of risks Comerica accepts. Comerica continuously enhances its enterprise risk framework with additional processes, tools and systems designed to not only provide management with deeper insight into Comerica's various existing and emerging risks in accordance with its appetite for risk, but also to improve Comerica's ability to control those risks and ensure that appropriate consideration is received for the risks taken.

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Comerica's front line employees, the first line of defense, are responsible for the day-to-day management of risks including the identification, assessment, measurement and control of risks encountered as a part of the normal course of business. Risks are further monitored, measured and controlled by the second line of defense, comprised of specialized risk managers for each of the major risk categories, who reside in the Enterprise Risk Division and provide oversight, independent and effective challenge and guidance for the risk management activities of the organization. The Enterprise Risk Division, led by the Chief Risk Officer, is responsible for designing and managing Comerica's enterprise risk framework and ensures effective risk management oversight. Risk management committees serve as a point of review and escalation for those risks which may have risk interdependencies or where risk levels may be nearing the limits outlined in Comerica's risk appetite statement. These committees comprise senior and executive management that represent views from both the lines of business and risk management. Internal Audit, the third line of defense, monitors and assesses the overall effectiveness of the risk management framework on an ongoing basis and provides an independent, objective assessment of Comerica's ability to manage and control risk to management and the Audit Committee of the Board.

The Enterprise Risk and Return Committee, chaired by the Chief Risk Officer, is established by the Enterprise Risk Committee of the Board, and is responsible for governance over the risk management framework, providing oversight in managing Comerica's aggregate risk position and reporting on the comprehensive portfolio of risks as well as the potential impact these risks can have on Comerica's risk profile and resulting capital level. Capital is the common denominator of risk. The Enterprise Risk and Return Committee is principally composed of senior officers and executives representing the different risk areas and business units who are appointed by the Chairman and Chief Executive Officer of Comerica.

The Board's Enterprise Risk Committee meets quarterly and is chartered to assist the Board in promoting the best interests of Comerica by overseeing policies and risk practices relating to enterprise-wide risk and ensuring compliance with bank regulatory obligations. Members of the Enterprise Risk Committee are selected such that the committee comprises individuals whose experiences and qualifications can lead to broad and informed views on risk matters facing Comerica and the financial services industry. These include, but are not limited to, existing and emerging risk matters related to credit, market, liquidity, operational, technology, compliance and strategic conditions. A comprehensive risk report is submitted to the Enterprise Risk Committee each quarter providing management's view of Comerica's aggregate risk position.

• For further information, refer to "Risk Management" on pages F-18 through F-34 of Comerica's 2023 Form 10-K.

CREDIT RISK

Credit risk represents the risk of loss due to failure of a customer or counterparty to meet its financial obligations in accordance with contractual terms. Comerica assumes credit risk in the normal course of business, predominantly from the extension of credit to businesses and individuals. Additionally, Comerica enters into transactions which give rise to counterparty credit risk involving derivative and credit-related financial instruments that meet the financing needs of customers.

Credit risk in the loan portfolio is managed through underwriting and periodically reviewing and approving its credit exposures using approved credit policies and guidelines. Additionally, Comerica manages credit risk through loan portfolio diversification, limiting exposure to any single industry, customer or guarantor, and selling participations and/or syndicating credit exposures above those levels it deems prudent to third parties. Refer to the "Counterparty Credit Risk" section of this report for a discussion of Comerica's management of counterparty credit risk.

For further discussion of credit risk, risk management objectives and policies and accounting policies related to these exposures:

• Refer to "Underwriting Approach" in Part I, Item 1 on page 11 of Comerica's 2023 Form 10-K.
• See the "Credit Risk" subheading on pages F-18 through F-26 in the "Risk Management" section of Comerica's 2023 Form 10-K.
• See Note 1 to the consolidated financial statements on page F-47 of Comerica's 2023 Form 10-K.

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Credit risk exposures

The following tables present certain of Comerica's positions which give rise to credit risk. The amounts do not include the effects of certain credit risk mitigation techniques, such as collateral and netting not permitted under GAAP.

Table 5: Credit Risk Exposures by Exposure Type, Counterparty Type and Domicile

March 31, 2024			Counterparty Type
				U.S.									Domicile (c)
			Public											Quarterly
Exposure Type		Banks	Sector	Corporate		Other	Netting	Total		U.S.		Non-		Total		Average
		(a)		(b)			U.S.			(d)
(in millions)
Cash and cash equivalents	$	879	$	4,256	$	-	$	-	$	-	$ 5,135	$	4,923	$	212	$	5,135	$	7,726
Debt securities		-	16,246		-		-		-	16,246		16,246		-		16,246		16,328
Loans		4		223		46,479		4,116		- 50,822 49,433 1,389 50,822		51,372
Derivatives		669		-		291		-		(422)	538		241		297		538		551
Total on-balance sheet	$	1,552	$	20,725	$	46,770	$	4,116	$	(422)	$72,741	$	70,843	$	1,898	$	72,741	$	75,977
Unfunded commitments	$	-	$	55	$	25,790	$	3,589	$	-	$29,434	$	28,749	$	685	$	29,434	$	30,409
Standby letters of credit		16		3		3,568		-		-	3,587		3,300		287		3,587		3,586
Total off-balance sheet	$	16	$	58	$	29,358	$	3,589	$	-	$33,021	$	32,049	$	972	$	33,021	$	33,995

1. Includes balances with Federal Reserve Banks, the U.S. government and its agencies, government-sponsored entities and states and municipalities.
2. Includes residential mortgage and consumer loans.
3. Based on legal domicile of the counterparty.
4. Average of daily or month-end balances where available; otherwise average of quarter-end balances.

Contractual maturities

Table 6: Remaining Contractual Maturity by Exposure Type

March 31, 2024				Maturing
				After 1 Year
Exposure Type		Within 1 Year		But Within 5		After 5 Years		Netting		Total
		Years
(in millions)
Cash and cash equivalents	$	5,135	$	-	$	-	$	-	$	5,135
Debt securities		922		941		14,383		-		16,246
Loans		15,321		27,368		8,133		-		50,822
Derivatives		461		400		99		(422)		538
Total on-balance sheet	$	21,839	$	28,709	$	22,615	$	(422)	$	72,741
Unfunded commitments	$	7,113	$	18,565	$	3,756	$	-	$	29,434
Standby letters of credit		3,192		394		1		-		3,587
Total off-balance sheet	$	10,305	$	18,959	$	3,757	$	-	$	33,021

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Nonaccrual and past due loans

Table 7: Nonaccrual and Past Due Loans

The following table provides details on nonaccrual and past due loans, the allowance for loan losses and charge-offs by counterparty type and domicile.

		Counterparty Type				Domicile (b)
March 31, 2024	Corporate	Other (a)		Total		U.S.		Non-U.S.		Total
(in millions)
Nonaccrual loans	$	171	$	46	$	217	$	201	$	16	$	217
Loans past due 90 days or more and still accruing		32		-		32		31		1		32
Allowance for loan losses		626		65		691
Gross charge-offs during the quarter		20		1		21

1. Includes residential mortgage and consumer loans.
2. Based on legal domicile of the counterparty.

Allowance for credit losses

• For a reconciliation of changes in the allowance for credit losses, see Note 4 to the consolidated financial statements on page 11 of Comerica's First Quarter 2024 Form 10-Q.

COUNTERPARTY CREDIT RISK

Counterparty credit risk is the risk that the counterparty to an over-the-counter ("OTC") derivative contract will be unable to meet their payment obligation. Exposure to counterparty credit risk on OTC derivative contracts is impacted by market volatility, which could increase or decrease potential future counterparty credit exposure. Comerica mitigates counterparty credit risk through the use of limits and monitoring procedures, as well as master netting arrangements, centrally clearing derivatives through a clearinghouse and bilateral collateral agreements. Comerica determines credit risk exposure limits by evaluating the creditworthiness of each counterparty, adhering to the same credit approval process used for traditional lending activities and obtaining collateral as deemed necessary. Included in the fair value of derivative instruments are credit valuation adjustments reflecting counterparty credit risk. These adjustments are determined by applying a credit spread for the counterparty or Comerica as appropriate, to the total expected exposure of the derivative.

Comerica generally uses the International Swaps and Derivatives Association, Inc. ("ISDA") master netting agreement to document derivative transactions. Master netting arrangements effectively reduce credit valuation adjustments by permitting settlement of positive and negative positions and offset cash collateral held with the same counterparty on a net basis.

Comerica may require collateral depending on the credit evaluation done for each of Comerica's counterparties. Where possible, Comerica makes use of bilateral collateral agreements, which require daily exchange of cash or highly rated securities issued by the U.S. Treasury or other U.S. government entities to collateralize amounts due to either party beyond specified thresholds.

• For information about valuation approaches, including for collateral, see Note 1 to the consolidated financial statements on page F-47 of Comerica's 2023 Form 10-K.

Counterparty credit risk exposures

• For information about OTC derivative counterparty risk exposure, including the impact of netting and collateral held and current credit exposure by exposure type, as well as information about the amount of collateral Comerica would have to provide given a credit rating downgrade, see Note 5 to the consolidated financial statements on page 17 of Comerica's First Quarter 2024 Form 10-Q.

Credit risk participations

Comerica enters into credit risk participation agreements to share the credit exposure related to certain derivative contracts with other counterparties (risk participations purchased) or to assume counterparty credit exposure related to certain derivative contracts (risk participations sold). Comerica enters into credit risk participation agreements in instances in which Comerica is also a party to a related loan participation agreement for such borrowers. Comerica will receive or make payments under these agreements if the borrower defaults on the derivative contract. In the event of default, the lead bank has the ability to liquidate the assets of the borrower, in which case the lead bank would be required to return a percentage of the recouped assets to the participating banks. Comerica manages credit risk on credit risk participation agreements sold by monitoring the creditworthiness of the borrowers, which is based on the normal credit review process had it entered into the derivative

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