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EXHIBIT 99.1
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 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 Incorporated elects to be a financial holding company.
2. Company and Each Depository Institution Subsidiary
The name of the company is Comerica 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
500 Woodward Avenue
Detroit, Michigan 48226
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Jack Wixted, Senior Vice President
Federal Reserve Bank of Chicago
November 28, 2000
Page 2
b.) Comerica Bank-California
333 W. Santa Clara Street
San Jose, California 95113
c.) Comerica Bank-Texas
Thanksgiving Tower
1601 Elm Street
Dallas, Texas 72201
d.) Comerica Bank, N.A.
3450 West Central Avenue
Suite 230
Toledo, Ohio 43606
e.) Comerica Bank & Trust, N.A.
101 North Main Street
Ann Arbor, Michigan 48104
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.
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Jack Wixted, Senior Vice President
Federal Reserve Bank of Chicago
November 28, 2000
Page 3
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
Page 4
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
<TABLE>
<CAPTION>
Tier 1 Tier 2 Risk-adj. Adj. Total Leverage Tier I Total
Capital Capital Assets Assets (i) Ratio (2) Ratio Ratio
------- ------- --------- ---------- --------- ------ -----
<S> <C> <C> <C> <C> <C> <C> <C>
Comerica Consolidated 3,501,522 2,018,126 49,795,692 40,191,509 8.71% 7.03% 11.08%
Comerica Bank 2,826,598 1,702,353 40,186,867 32,325,393 8.74% 7.03% 11.27%
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%
Comerica Bank, N,A. 8,845 -- 2,346 10,241 86.37% 377.02% 377.02%
Comerica Bank & Trust, N.A. 1,124 -- 508 1,495 75.18% 221.26% 221.26%
</TABLE>
(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.
