Political Activities and Contributions

The financial services industry is subject to regulation at all levels of government. Changes in federal, state and local laws can have a major impact on our businesses. As such, Comerica Incorporated (Comerica) is committed to diligently monitoring and participating in the political process.

Government Relations Group

The Government Relations Group is part of Comerica's Governance, Regulatory Relations and Legal Affairs Department. The group works closely with the three major business segments — Business Banking, Retail Banking and Wealth & Institutional Management — to manage the company’s legislative and political activities, including the Comerica Political Action Committee.

Political Action Committee

One way Comerica participates in the political process is through contributions from its political action committee (PAC). The PAC annually solicits contributions from eligible employees and makes bipartisan contributions — all in compliance with local, state and federal election laws — to political candidates and committees who understand and support Comerica’s pro-banking, pro-business philosophy. All political contributions and guidelines are developed and approved by a separate PAC Board comprised of senior executives from across the company’s major business segments.

While Comerica colleagues are encouraged to participate in the political process on their own time, they are not pressured to make personal contributions. Personal political contributions made by Comerica colleagues will not be reimbursed directly or indirectly by the company.

Comerica does not use corporate funds to make direct political contributions to candidates for public office or groups organized to influence political campaigns under Section 527 of the Internal Revenue Code. From time to time, however, Comerica will contribute corporate funds to support state and local ballot initiatives if the company believes that passage of such initiatives will enhance the quality of life in the communities where our customers and employees live, work and raise their families.

For a complete list of Comerica PAC contributions between 11/1/12 and 10/31/13, please see the document below. This list is updated annually in November.

Trade Association Memberships

Comerica belongs to several financial services-related trade associations across the country. Membership benefits include numerous business opportunities for the company and effective grassroots advocacy on behalf of the industry. A portion of the trade association dues that Comerica pays are used for lobbying and/or political activities and are non-deductible under Section 162(e)(1) of the Internal Revenue Code.

For a list of trade associations to which Comerica belongs, as of 11/1/13, please see the document below. This list is updated annually in November.

For More Information

If you have any questions about the Government Relations Group and Comerica’s legislative and political activities, please contact Dan Donohoe, Director of Government Relations, at ddonohoe@comerica.com.





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