Comerica Incorporated : 2023 Comerica Corporate Responsibility Report - PDF (

2023

Corporate Responsibility Report

Raise Your Expectations®

A comprehensive review of Comerica's environmental, social and governance practices and progress

The disclosures included in this document are being provided to the public in an effort to provide transparency into our environmental, social and governance (ESG) initiatives, to respond to stakeholder requests, and to further enhance our stakeholders' understanding of corporate responsibility practices at Comerica. This report is provided for informational purposes only and is not intended as advertising, or marketing material, or as an offer or recommendation to purchase any asset, product or service. Our approaches to the disclosures included in this document differ in significant ways from those included in mandatory regulatory reporting, including under U.S. Securities and Exchange Commission rules and regulations and applicable stock exchange listings, and may consider different and broader definitions of materiality promulgated by other frameworks and reporting guidelines that take into consideration a wider range of factors. Thus, while certain matters discussed in this document may be significant, any significance should not be read as necessarily rising to the level of materiality used for the purposes of complying with the U.S. federal securities laws, or any other regulatory purpose. Information and metrics in these disclosures are unaudited, reliant on methodologies which continue to evolve, and cite third-party information that we do not independently verify. For example, standards for accounting for and measuring impact and greenhouse gas (GHG) emissions, as well as measuring GHG emissions reductions, vary, including due to the underlying emissions factors, assumptions or other methodological features. Any changes to methodologies or the information we have cited may change our disclosures.

Any statements in this document that are not historical facts are forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. Words such as "achieve, anticipate, aspire, assume, believe, can, commit, confident, continue, could, designed, estimate, expect, feel, forecast, forward, future, goal, grow, initiative, intend, look forward, maintain, may, might, mission, model, objective, opportunity, outcome, on track, outlook, plan, position, potential, project, propose, remain, seek, should, strategy, strive, target, trend, until, well-positioned, will, would" or similar expressions, as they relate to Comerica, or to economic, market or other environmental conditions or its management, are intended to identify forward-looking statements. These forward-looking statements are predicated on the beliefs and assumptions of Comerica's management based on information known to Comerica's management as of the date of this document and do not purport to speak as of any other date. Forward-looking statements may include descriptions of plans and objectives of Comerica's management for future or past operations, products or services, and forecasts of Comerica's revenue, earnings or other measures of economic performance, including statements of profitability, business segments and subsidiaries as well as estimates of credit trends and global stability. Such statements reflect the view of Comerica's management as of the date of this document with respect to future events and are subject to risks and uncertainties. Should one or more of these risks materialize or should underlying beliefs or assumptions prove incorrect, Comerica's actual results could differ materially from those discussed. Factors that could cause or contribute to such differences include credit risks (changes in customer behavior; unfavorable developments concerning credit quality; and declines or other changes in the businesses or industries of Comerica's customers); market risks (changes in monetary and fiscal policies; fluctuations in interest rates and their impact on deposit pricing; and transitions away from the Bloomberg Short-Term Bank Yield Index towards new interest rate benchmarks); liquidity risks (Comerica's ability to maintain adequate sources of funding and liquidity; reductions in Comerica's credit rating; and the interdependence of financial service companies and their soundness); technology risks (cybersecurity risks and heightened legislative and regulatory focus on cybersecurity and data privacy); operational risks (operational, systems or infrastructure failures; reliance on other companies to provide certain key components of business infrastructure; the impact of legal and regulatory proceedings or determinations; losses due to fraud; and controls and procedures failures); compliance risks (changes in regulation or oversight, or changes in Comerica's status with respect to existing regulations or oversight; the effects of stringent capital requirements; and the impacts of future legislative, administrative or judicial changes to tax regulations); strategic risks (damage to Comerica's reputation; Comerica's ability to utilize technology to efficiently and effectively develop, market and deliver new products and services; competitive product and pricing pressures among financial institutions within Comerica's markets; the implementation of Comerica's strategies and business initiatives; management's ability to maintain and expand customer relationships; management's ability to retain key officers and employees; and any future strategic acquisitions or divestitures); and other general risks (changes in general economic, political or industry conditions; negative effects from inflation; the effectiveness of methods of reducing risk exposures; the effects of catastrophic events, including pandemics; physical or transition risks related to climate change; changes in accounting standards; the critical nature of Comerica's accounting policies, processes and management estimates; the volatility of Comerica's stock price; and that an investment in Comerica's equity securities is not insured or guaranteed by the FDIC). Comerica cautions that the foregoing list of factors is not all-inclusive. For discussion of factors that may cause actual results to differ from expectations, please refer to our filings with the Securities and Exchange Commission. In particular, please refer to "Item 1A. Risk Factors" beginning on page 14 of Comerica's Annual Report on Form 10-K for the year ended December 31, 2023. Forward-looking statements speak only as of the date they are made. Comerica does not undertake to update forward-looking statements to reflect facts, circumstances, assumptions or events that occur after the date the forward-looking statements are made. For any forward-looking statements made in this or in any other documents, Comerica claims the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995.

Table of Contents

Message from Our Chairman,	4
President and CEO
Message from Our Executive Vice President
of Corporate Responsibility	5
About This Report	6
About Comerica	7
Our Company	7
Our Core Values	8
2023 Corporate Responsibility Recognition	10
2023 Financial Highlights	10
Corporate Responsibility at Comerica	11
Our Corporate Responsibility Approach	12
Our Corporate Responsibility Platform	12
Impact and Stakeholder Engagement	13
Corporate Responsibility Platform Alignment	16
Oversight of Corporate Responsibility at Comerica	17
Customers	19
Comerica's Promise	20
Ensuring The Customer Comes First	21
Small Business Support	22
Innovation and Technology	26
Financial Inclusion	28
ESG-Related Lending and Investment	30

Colleagues	31
Talent Attraction	33
Learning and Development	34
Employee Engagement	36
Compensation and Benefits	38

Diversity, Equity and Inclusion	40
Workforce and Board Diversity	42
DEI Governance and Priorities	44
Attracting Diverse Talent	47
Educating Our Colleagues	49
Diversity Employee Resource Groups (ERGs)	50
2023 DEI Awards	51
Supplier Diversity	52
Amplifying Our DEI Impact	53

Community	54
Empowering and Strengthening Our Communities	55
Financial Education	59
Business Resource Groups	60
Volunteerism and Philanthropy	61

Environment	65
Climate Change	66
Reducing GHG Emissions	68
Reducing Paper, Waste and Water Impacts	70
Reducing Environmental Risk Through	72
Credit and Lending Practices
Environmentally Beneficial (Green) Loans	73
Driving Sustainability Engagement	76
and Awareness

Responsible Business	78
Business Risk Management	79
Enterprise Security	82
Privacy and Data Protection	85
Compliance and Ethics	86
Human Rights	88
Fair and Responsible Banking	88
Public Policy and Government Relations	89

Additional Information	90
Key Metrics Tables	91
Reporting Methodology	107
GRI Standards Content Index	108
SASB Standards Content Index	134

	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

Message from Our Chairman, President and CEO

Comerica is pleased to share our 16th annual corporate responsibility report, which includes a summary of Comerica's progress on key environmental, social and governance issues.

"Responsible business is good business. And part of our commitment as a responsible

business is being there for our customers and communities with Comerica's strength, stability and longevity."

Comerica has a long-standing belief that our business delivers much more than shareholder returns. This unwavering commitment helps businesses and individuals meet their financial needs, empowers them to thrive and contributes to the communities we serve. Our place in the banking industry gives us the unique opportunity to be embedded in our communities while providing the scale and expertise to support our customers' most sophisticated needs.

Comerica has a long history of addressing social and environmental matters. We believe this is one of the many reasons Comerica continues to deliver solid financial and nonfinancial returns to our stakeholders. Quite simply, responsible business is good business. And, part of our commitment as a responsible business is being there for our customers and communities with Comerica's strength, stability and longevity.

Throughout this 16th annual report, you will find examples of Comerica's commitment to our Core Values, particularly that of being a Force For Good. These Core Values reinforce the mission behind our work and the efforts our colleagues make to deliver above and beyond traditional banking services. And, our Corporate Responsibility Platform provides the framework that addresses the critical issues of financial education, diversity, climate change, access to capital and products, and services that support environmental and social needs.

Thank you to all our stakeholders for their contributions, which enable Comerica to continue to be A Force For Good and deliver lasting and powerful impacts. As we look to our 175th anniversary in 2024, we expect to continue to deliver on our promise to raise expectations of what a bank can be. We look forward to continuing our progress on creating positive change for our customers, communities and the world around us.

Curtis C. Farmer

Chairman, President and Chief Executive Officer,

Comerica Incorporated and Comerica Bank

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

Message from Our Executive Vice President of Corporate Responsibility

While we've seen many changes over the course of Comerica Bank's history, one thing that hasn't wavered is our dedication to positively impacting our customers, communities and colleagues.

"Corporate responsibility isn't merely a requisite at Comerica - it is an integral part of our organization's identity and is embedded in our Core Values."

We made great strides in advancing our social and environmental efforts in 2023, and we're proud to share the results.

In May, we redefined how a bank can serve the needs of its community when we launched Comerica BusinessHQ in Dallas. Seeking to empower entrepreneurs and small business owners in Dallas' Southern sector, we opened the doors to a state-of-the-art facility that delivers tools to help them develop, grow and endure. Also in support of small businesses, we surpassed our three-year(2021-2023), $5 billion small business lending commitment that delivered meaningful funding to thousands of small businesses.

Our colleagues remain steadfast in serving our communities, stepping up to contribute more than 79,000 volunteer hours in 2023 alone. Their volunteer time included delivering financial education to low- to moderate-income communities through our Comerica Money $ense programs, reaching nearly 106,000 individuals, and through small business bootcamps, which assisted more than 8,000 entrepreneurs and small business owners.

Our commitment to building a more sustainable future is evidenced by the increase we saw in green loans and commitments - ending 2023 at $2.9 billion. We proudly remain a corporate sustainability leader, earning national recognitions for our work, as highlighted by our listing on Newsweek's America's Most Responsible Companies for the fifth consecutive year.

And as with any company that has served customers for nearly 175 years, maintaining trust is essential. Consistency, transparency and diligence has earned the confidence of our customers, colleagues and communities.

We strive to exceed the expectations of our stakeholders and make an impact that extends beyond just banking. As we approach our 175th anniversary, we look forward to continuing our legacy of building stronger communities and making a positive impact that resonates now and for generations to come.

Wendy Bridges

Executive Vice President,

Executive Director of Corporate Responsibility

Comerica Bank

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

About This Report

From diversity and environmental protection to risk management and innovation, corporate responsibility is central to how we operate at Comerica. This 16th annual Corporate Responsibility Report showcases our deep commitment to driving progress in these areas. While there is always more work to do, we will continue to move forward with the goal of ensuring that our company, colleagues, customers, communities and other stakeholders thrive, now and long into the future.

Our reporting generally aligns with the following standards:

GRI (Global Reporting	Overall reporting structure and approach to disclosing the
Initiative)	topics most significant to Comerica and our stakeholders.
SASB (Sustainability	Highlighting corporate responsibility topics for the
Accounting Standards	commercial banking sector.
Board)
TCFD (Task Force on	Illustrating Comerica's approach to the strategy,
Financial-related	governance, risk management, metrics and targets related
Disclosures)	to climate change.
CDP	Providing disclosure of greenhouse gas (GHG) emissions
	and related approaches to climate risks and opportunities.
UN SDGs (Sustainable	Allows for alignment with global goals as our call to action
Development Goals)	to help end poverty and inequality, protect the planet, and
	ensure health, justice and prosperity for all.

The information and scope of performance data in this report is company-wide for the fiscal year ending December 31, 2023, and all financial information is presented in U.S. dollars, unless otherwise noted.

While this Corporate Responsibility Report has not been externally assured, we annually assure our Scope 1, 2 and 3 greenhouse gas (GHG) emissions using ISO 14064-3 (limited assurance, GHG emissions assurance letter for 2023 emissions). Additional GHG emissions assurance details are provided in our most recent CDP Response.

The Reporting Methodology section of this report contains additional details regarding the standards we use and our approach to corporate responsibility reporting. We also include GRI and SASB content indices which are in the Additional Information section of this report.

For additional information on corporate responsibility activities and disclosures, please see:

2022 Comerica	Comerica 2023	Most Recent
Corporate	Annual Report	CDP Response
Responsibility Report

2023 TCFD Report	2024 Proxy Statement Environmental Policy
	Statement

In this report and in Comerica's prior corporate responsibility reports, we use the term "impact" to refer to topics that reflect the environmental, social and governance issues most important to Comerica and our stakeholders - what the Global Reporting Initiative (GRI) Sustainability Reporting Standards refer to as "Material Topics." This is to avoid potential confusion with the terms "material" or "materiality" as defined by or construed in accordance with securities laws or other U.S. legislation or as used in the context of financial statements and financial reporting.

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

About Comerica

Our Company

Founded in 1849, Comerica (NYSE: CMA) is a financial services company headquartered in Dallas, Texas. While a lot has changed since our founding, one thing remains the same - our commitment to serving the financial needs of our customers and communities.

Comerica is one of the 25 largest commercial U.S. financial holding companies and focuses on building relationships and helping people and businesses be successful. We are strategically aligned by three business segments: The Commercial Bank, The Retail Bank and Wealth Management. Comerica provides more than 400 U.S. banking centers as of Dec. 31, 2023, with locations in Arizona, California, Florida, Michigan and Texas. Founded on August 17, 1849, in Detroit, Michigan, Comerica continues to expand into new regions, including its Southeast Market, based in North Carolina, and Mountain West Market in Colorado. Learn more about how Comerica is raising expectations of what a bank can be by visiting www.comerica.com and following us on Facebook,X, Instagram and LinkedIn.

CREATING POWER AND STABILITY THROUGH A PRUDENT, CONSERVATIVE

BANKING APPROACH

Award-winning	With expertise spanning a number of different industries and
relationship	markets, our bankers have the knowledge and skills needed to
banking	refine solutions tailored to meet the needs of those we serve.
Strong credit	We have consistent, conservative underwriting standards and
fundamentals	balanced exposure to a wide variety of industries across multiple
	markets, helping to minimize the impact of economic downturns.
Providing the	As a regional bank, Comerica occupies a unique niche in the
best of both	banking industry, combining a number of "big bank" products and
worlds	services with a more localized and personalized touch reminiscent
	of community banks.
The right markets	Comerica offers its financial services and expertise in some of the
and right model	fastest-growing and most vibrant regions in America. We have
	offices in 17 states and service 14 of the 15 largest U.S.
	metropolitan areas as well as Canada and Mexico.

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

Our Core Values

Comerica's Core Values represent how we connect with our colleagues, customers and other stakeholders. Based on concepts that are simple, memorable, inspirational and actionable, our Core Values reinforce our culture in a way that resonates with every colleague.

Why We Are Here

To raise expectations of what a bank can be for our colleagues, customers and communities

What We Believe

How We Deliver

ONE COMERICA

We believe that growth is achieved

when our colleagues act with common purpose in support of shared goals.

THE BIGGER POSSIBLE

We encourage a culture of bold and relentless curiosity, where any idea has a chance to be heard.

THE CUSTOMER COMES FIRST

We put our customers at the

center of every conversation and

make their satisfaction our

highest priority.

A FORCE FOR GOOD

We value empathy and integrity as we

work to create a more diverse,

inclusive and sustainable workplace

and world.

TRUST. ACT. OWN.

Everyone is empowered to do what's best for both our customers

and colleagues.

Speak up, be heard and make things happen when you see a chance to improve

our culture and the customer experience.

Be accountable for your actions and always follow through on your commitments.

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

Our Promise

We will Raise Your Expectations® of what a bank can be.

This promise guides our interactions with customers and reflects our deep, unwavering commitment to provide them with the service, knowledge and positive experience that meets their desires and exceeds their expectations.

Our strategically aligned business segments are set up to help ensure that individuals and businesses are successful:

The Commercial Bank

Provides companies of all sizes with an array of credit and non-credit financial products and services.

The Retail Bank

Delivers personalized financial products and services to consumers.

Year-End 2023: Business at a Glance

174	407	$85.8
years in operation		U.S. banking centers		billion in assets
$52.1	$66.8	$3.6
billion in loans		billion in deposits		billion in revenue

Year-End 2023: Our Team

Wealth Management

Serves the needs of high-net-worth clients and institutions.

7,496

full-time U.S. colleagues

63%

of U.S. colleagues are female

367

part-time U.S. colleagues

43%

of U.S. colleagues are racial/ethnic minorities

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	About This	About	Corporate			Diversity, Equity			Responsible	Additional
CEO Letter	Responsibility	Customers	Colleagues	Community	Environment
Report	Comerica	and Inclusion	Business	Information
	at Comerica

2023 Corporate Responsibility Recognition

Ranked among Newsweek's listings of America's Most Responsible Companies for fifth consecutive year and the inaugural America's Greenest Companies

Named to the list of America's Most JUST Companies

Greenwich Excellence and Best Brand Awards in 2023 for Small Business Banking

2023 American Bankers Association Foundation Community Commitment Award in the volunteerism category for Comerica Cares program

2023 Brandon Hall Bronze Award Winner for Best Unique or Innovative Leadership and Development Program for the Comerica Year of the Manager program

Recipient of Top Workplaces 2023 awards from The Dallas Morning News and Detroit Free Press

Wilkinson Center's 2023 Volunteer Group of the Year

For recognition specific to our Diversity, Equity and Inclusion (DEI) and additional Community efforts, see the 2023 DEI Awards sub-section of this report.

2023 Financial Highlights

Although 2023 was challenging for our industry, it also was a year of achievement. Following industry disruptions, we protected relationships, stabilized deposits, maintained strong credit quality, enhanced our capital and took steps to help position our business for future success. Despite the volatility, we delivered impactful banking solutions to small businesses, enhanced capabilities for wealth management clients through a strategic partnership with Ameriprise Financial (Ameriprise) and continued technology and product modernization. Through our support of financial education, economic development and human services programming, we continued to positively impact our local communities and received an Outstanding Community Reinvestment Act rating.

Robust, broad-based loan growth, coupled with rising rates, drove a 2% increase in our revenue to an all-time high of over $3.6 billion. We produced record average loans of $53.9 billion and the highest year of net interest income in our history. In all, we produced a return on equity of 16.50%, return on assets of 1.01% and earnings per share of $6.44.

	$53.9B					$2.51B		0.04%
	Record Loans					Record Net Interest Income				Net Charge-offs Remained
	($ in billions; avg.)					($ in billions)					Excellent
$49.1	$50.5	$53.9												0.04%
											0.03%
								$2.47	$2.51
					$1.84
										(0.02)%
2021	2022	2023		2021	2022	2023	2021	2022	2023
	Continued Strong Capital	Strategic Deposit			Strong Noninterest Income
	(Common Equity Tier 1)	Management			($ in billions)
					($ in billions; avg.)
10.13%	10.00%	11.09%		$77.7	$75.5	$66.0
										$1.12	$1.07	$1.08
2021	2022	2023		2021	2022	2023	2021	2022	2023

For additional information, view our 2023 Comerica Incorporated Annual Report and 2024

Proxy Statement.

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