Comerica Inc (CMA) 2009 Q2 法說會逐字稿

Good morning.

My name is Celeste, and I will be your conference operator today.

At this time, I would like to welcome everyone to the Comerica second quarter 2009 conference call.

All lines have been placed on mute to prevent any background noise.

After the speakers' remarks, there will be a question and answer session.

(Operator Instructions).

Thank you.

Ms.

Persons, you may now begin.

Thank you, Celeste.

Good morning, and welcome to Comerica's second quarter 2009 earnings conference call.

This is Darlene Persons, Director of Investor Relations.

I am here with our Chairman, Ralph Babb, our Chief Financial Officer, Beth Acton, and Dale Greene, our Chief Credit Officer.

A copy of our earnings release, financial statements, and supplemental information is available on the SEC's website, as well as on our website.

Before we get started, I would like to remind you that this conference call contains forward-looking statements, and in that regard, you should be mindful of the risks and uncertainties that can cause future results to vary from expectation.

I refer you to the Safe Harbor Statement contained in the earnings release issued today, which I incorporate into this call, as well as our filings with the SEC.

Also, this conference call will reference non-GAAP financial measures.

In that regard, I will direct you to the calculation of such measures within the earnings release and presentation.

Now, I will turn the call over to Ralph.

Good morning.

The second quarter results reflect the difficult economic environment, particularly the residential real estate development challenges.

We are managing through this environment by quickly identifying problem loans, building our loan loss reserve, credit by credit, and strengthening our already solid capital position.

While there are some signs the economy may be bottoming, businesses and individuals are still feeling the effects of this prolonged recession.

They remain cautious in an environment in which unemployment rates have continued to rise.

Impacting our performance in the second quarter was a provision for loan losses of $312 million, up $109 million from the first quarter, as well an industry-wide FDIC special deposit assessment of $29 million.

Largely offsetting the provision increase and the FDIC special assessment were $113 million of net securities gains related to our investment portfolio.

We had $18 million in net income in the second quarter, compared to $9 million in the first quarter.

Preferred stock dividends to the US Treasury Department under the capital purchase program were $34 million, or $0.22 per share, resulting in a net loss applicable to common stock of $16 million or $0.10 per share.

We had $10.2 billion in new and renewed lending commitments in the second quarter, up from $5.6 billion in the first quarter, with the increase due in large part to the seasonality of renewals.

New commitments totaled $1.6 billion in the second quarter, up from $1.4 billion in the first quarter.

We continued to focus our lending efforts on new and existing relationship customers, with the appropriate credit standards and return hurdles in place.

Like the industry, as a whole, however, we continue to see weak loan demand across our geographic markets.

This mirrors the sharp slowdown in commercial and industrial growth that was evident in all 10 post-World War II recessions.

Overall, our average loans, excluding the Financial Services division were down $1.9 billion from the first quarter.

We had very strong deposit generation in the second quarter, with average core deposits up $1.1 billion compared to the first quarter lead by $1 billion in average in average non-interest bearing deposits.

As expected, the net interest margin improved 20 basis points in the second quarter to 2.73%, compared to the first quarter, driven by increasing loan spreads and maturities of higher cost time deposits.

Our capital ratios increased from already strong levels, as evidenced by a tangible common equity ratio of 7.55%.

A top corporate priority for us is to redeem the $2.25 billion in preferred stock at such time is feasible with careful consideration given to the economic environment, which continues to be challenging.

The key credit issue for us remains in our commercial real estate line of business predominantly residential real estate development.

We have seen signs of stabilization in the residential real estate portfolio in California.

Texas has held up relatively well, and we have been working through issues related to falling home prices in Michigan for several years.

Florida had performed well for us but the prolonged recession has recently taken a toll on our residential real estate development portfolio in that state as well as in other markets.

We are managing these problem loans effectively.

We are conducting in depth reviews, obtaining current independent appraisals, taking the appropriate charge-offs, and providing incremental reserves to reflect the challenges of this difficult economic environment.

In fact, our non-performing loans have been charged down 39%.

With regard to the automotive industry, we have anticipated and planned for the restructuring now under way and no longer have any direct exposure to Chrysler or General Motors.

Our top tier mega franchise auto dealer strategy continues to work well for us.

We have maintained excellent credit quality within our auto dealer portfolio, with no non-accruals or charge-offs in the Second Quarter.

We have no material exposure to dealers which are closing.

Within our automotive supplier portfolio, which we have continued to reduce, many of our customers who supply GM or Chrysler have been named as essential suppliers by both those automakers.

As a result, they are expected to continue to operate.

Excluding a $21 million charge off related to General Motors leverage lease, net auto-related charge-offs in the second quarter remained at a low level.

Our expense controls continued in the second quarter.

Excluding the FDIC special assessment charge, annualized non-interest expenses remained nearly 10% below non-interest expenses for the full year 2008.

Looking ahead to the rest of the year, we believe loan demand will continue to be subdued.

We expect the third quarter net interest margin to be relatively unchanged from the second quarter with margin expansion resuming in the fourth quarter.

With no significant further deterioration of the economic environment, we expect net credit related charge-offs in the third quarter to be similar to the second quarter and to improve modestly in the fourth quarter.

Our expense controls are expected to continue.

Finally we expect to have additional securities gains from the sale of mortgage backed government agency securities.

We believe our proactive management of problem loans, building and reserves, expense controls and strong capital ratios position us well for the future.

And now I'll turn the call over to Beth and Dale who will discuss our second quarter results in more detail.

Thank you, Ralph.

As I review our second quarter results, I will be referring to slides we have prepared that provide additional details on our earnings.

Turning to slide three, we outlined the major components of our second quarter results compared to prior periods.

Today we reported second quarter 2009 earnings of $18 million.

After preferred dividends of $34 million, the net loss applicable to common stock was $16 million or $0.10 per diluted share.

Slide four provides an overview of the financial results from the quarter.

Average earning assets decreased $2.2 billion including a $1.9 billion decline in loan outstandings excluding Financial Services division.

The continuing slowdown in the economic environment has resulted in lower loan demand in all of our markets.

In addition, we reduced our investment securities portfolio as we no longer need downside interest rate protection and took advantage of favorable market conditions to sell securities at a substantial gain.

We had very strong deposit generation again in the second quarter with core deposits excluding Financial Services division increasing over $1.1 billion including a $1 billion increase in non-interest bearing deposits.

As expected, the net interest margin in the second quarter increased 20 basis points, primarily reflecting increased loan spreads, reduced deposit rates and the maturing of higher cost time deposits.

Net credit related charge-offs were $248 million.

We have written down non-performing loans by 39% compared to 28% a year ago.

The allowance to total loans increased by $64 million in the second quarter to 1.89% compared to 1.68% in the first quarter as we continued to reserve for loan losses substantially in excess of charge-offs.

We continued to successfully control expenses.

The second quarter results reflected the decrease in salaries, incentives and share based compensation over year ago levels.

Our workforce has been reduced by approximately 1000 positions or nearly 10% since June 2008.

Our cost cutting efforts were somewhat offset by rising FDIC and pension expenses.

The FDIC imposed on all banks higher insurance costs, as well as a special assessment in the second quarter which for Comerica was $29 million.

Excluding the FDIC special assessment charge, annualized non-interest expenses remain nearly below 10% for non-interest expenses for full year 2008.

The provision for income taxes decreased $58 million from the first quarter, primarily due to a change in the method of determining quarterly federal taxes.

The second quarter 2009 provision for income taxes also was reduced by $8 million of net adjustments including settlements related to federal and state tax audits.

Our capital position is strong and was further enhanced in the second quarter.

The Tier 1 capital ratio increased to an estimated 11.57% at June 30.

In addition the quality of our capital is solid as evidenced by our tangible common equity ratio of 7.55%.

Turning to slide five, average loan outstandings declined in the second quarter compared to the first quarter as a result of low demand in all of our markets.

Customers experienced lower sales volumes and continued to decrease inventory levels as they cautiously manage their businesses in the recessionary environment.

For example, in line with falling auto sales, national dealer services average outstandings were down $445 million or 11% from the First Quarter.

Larger average decreases in the second quarter were also noted in middle market, technology and life sciences, global corporate banking and commercial real estate.

We saw growth in private banking and mortgage banker finance which falls within our specialty businesses.

Markets outside of the Midwest comprise 63% of average loans.

In addition our loan portfolio was well diversified among many business lines.

Line utilization was 51% in the second quarter, down 1.6 percentage points from the first quarter.

Decreased commitments were more than matched with decreased outstandings, particularly in dealer, global corporate banking and middle market.

On slide six, we provide details of our investment securities portfolio.

We proactively sold $2.3 billion of mortgage backed government agency securities in the second quarter.

In late 2007 and throughout 2008, we significantly increased the size of the portfolio to dampen the effect of the decline in interest rates that has served its purpose well.

We purchased the securities at very attractive prices and widespreads relative to US Treasuries.

Further interest rate reductions are unlikely, so the need to hedge declining interest rate risk has diminished.

Also, given heightened mortgage refinancing activity, we have seen increased prepayments on the securities.

Last, present market prices are at levels we haven't seen in at least five years.

For all these reasons, it was prudent to reduce the size of the portfolio at this time.

Our goal is to maintain the portfolio at about 10% of assets.

As shown on slide seven, we had very strong deposit growth again in the second quarter in all of our markets and from both commercial and retail customers.

Average core deposits excluding Financial Services division increased over $1.1 billion, including a $1 billion increase in non-interest bearing deposits.

Total average personal banking deposits increased $262 million or 8% on an annualized basis.

As far as commercial accounts, non-interest bearing balances, excluding Financial Services division increased over $900 million.

Deposit pricing additions remained competitive in the Second Quarter and we believe we've hit rate floors on a number of our products; however we were able to selectively decrease rates in certain deposit categories.

Slide eight outlines the major factors that impacted the net interest margin in the second quarter.

The net interest margin increased 20 basis points from the first quarter primarily as a result of our continued success in expanding loan spreads and selectively reducing deposit pricing, combined with maturities of higher cost time deposits.

In the second quarter excess liquidity had an approximately eight basis point negative effect on the margin.

The excess liquidity resulted from strong deposit growth, the sale of mortgage backed government agency securities, combined with weak loan demand.

As a result, we had an average of $1.8 billion deposited with the Federal Reserve bank in the second quarter.

Now Dale Greene, our Chief Credit Officer, will discuss credit quality starting on slide nine.

Good morning.

In the second quarter, net credit related charge-offs and the provision for loan losses increased as the macroeconomic conditions continued to be challenging.

Particularly in real estate development in Florida and middle market in the Midwest.

Net credit related charge-offs were $248 million in the second quarter.

Net charge-offs included $108 million in the commercial real estate line of business, primarily related to residential real estate development up from $74 million in the first quarter.

The increase in commercial real estate charge-offs reflected the continued deterioration in values we are seeing as we obtain updated appraisals.

Provision for credit related losses of $308 million exceeded charge-offs by 60.

Turning to slide 10, non-performing assets were 264 basis points of total loans and foreclosed property or 134 basis points excluding the commercial real estate line of business.

Growth of our watch list loans slowed, totaling $7.4 billion at the end of the second quarter.

In line with the economic environment, the commercial real estate line of business and middle market particularly in Michigan continued to drive the negative migration.

As expected, foreclosed property totaled $100 million and reflects our efforts to work through the issues in the residential real estate development portfolio.

Loans past due 90 days or more and still accruing interest increased slightly to $210 million.

Most of these loans are resolved quickly as evidenced by the fact that only a few of the names from last quarter remain in this category.

Early delinquency or loans past due 30-89 days and still accrues decreased to $371 million from $495 million last quarter.

The allowance for loan losses was 1.89% of total loans, an increase of 21 basis points from the first quarter.

The allowance for loan losses was 78% of non-performing loans.

We have written down our non-accrual loans by 39%, which reflects current appraised values.

In addition, it is important to note that Comerica's portfolio is heavily composed of commercial loans, which in the event of default, are typically carried on the books as non-performing assets for a longer period of time than our consumer loans, which typically charged off when they become non-performing.

Therefore, banks with a heavier commercial loan mix in their portfolios tend to have lower NPA coverage ratios than do retail focused banks.

On slide 11, we provide information on the makeup of the non-accrual loans.

The largest portion of the non-accrual loans continues to be commercial real estate, which consisted primarily of residential real estate development loans.

By geography, 40% of non-accruals are in the western market and 31% are in the Midwest market.

During the second quarter 2009, $419 million of loan relationships greater than $2 million were transferred to non-accrual status, $204 million were in the commercial real estate business line, $79 million were in middle market and $78 million were in global corporate.

On slide 12, we provide a break down of net credit related charge-offs by office of loan origination.

Western market charge-offs declined in the second quarter with charge-offs in the commercial real estate line of business down $13 million.

Texas continued to perform well.

Net charge-offs for the Midwest, which made up 40% of the total, were primarily comprised of $35 million in middle market, $21 million in leasing, $20 million in the commercial real estate line of business, and $13 million in small business.

As far as Florida and other markets which includes national developers, the real estate development portfolio had been performing relatively well; however, the prolonged recession has taken a toll on our portfolio and net charge-offs for these segments increased in the second quarter.

Slide 13 provides detail on net loan charge-offs by line of business.

The commercial real estate line of business continues to drive the charge off levels.

We also had increases in Midwest middle market as expected in the current economic environment.

The increase in specialty businesses was primarily related to a lease arrangement.

Charge-offs for wealth and institutional management and small business were stable.

On slide 14 we provide detail on our shared national credit relationships.

Shared national credit outstandings were $10.7 billion at the end of the second quarter, a $758 million decline from the first quarter and a $1.2 billion decrease from year-end.

This category is very granular consisting of over 1000 borrowers.

It is also well diversified by both line of business and geography.

More than half of our shared national credit exposure is in areas where we maintain large corporate relationships, primarily in commercial real estate and global corporate banking.

In other areas, particularly middle market, we have worked to manage our exposure to customers by arranging HUB facilities, inviting two or three other banks into a facility.

Shared national credit loans are defined as facilities greater than $20 million and shared by three or more financial institutions.

We do not compromise our credit standards, return expectations or exposure guidelines in order to participate in the syndicated facility.

The credit issues we are seeing with shared national credits are similar to those we've seen in the book as a whole, which are primarily driven by residential real estate development.

On slide 15, we provide a detailed break down by geography and project type of our commercial real estate line of business, which declined slightly from the prior quarter.

There is further detail provided in the appendix to these slides.

At June 30, 28% of this portfolio consisted of loans made to real estate developers secured by the underlying real estate.

Total single family construction outstandings were down almost $600 million or over 40% from a year ago.

Michigan outstandings of $701 million represented 14% of the portfolio and were down $141 million or 17% from a year ago.

Florida outstandings of $646 million represent a 12% of the portfolio.

Turning to slide 16 and the geographic break down of net loan charge-offs for the commercial real estate line of business, residential real estate development loans accounted for the bulk of these charge-offs in the second quarter.

Charge-offs decreased in the western market while Texas and Midwest remains stable.

Florida, including exposure within our national developer portfolio, has limited land exposure and single family housing exposure has been managed down for some time in response to deteriorating market conditions.

Therefore, charge-offs early in the cycle were relatively minimal.

Large condominium projects that required a long buildout time, 24 to 36 months, are now being delivered and the construction risk is gone.

We have been closely watching these projects and have adjusted risk ratings and reserves as appropriate.

In general, our customers have been able to manage through the very challenging market conditions in Florida, completing their projects with substantial pre-sales.

Closings are occurring but at a very low level.

Many pre sales have been unable to close, as buyers have had difficulty obtaining mortgages, or have walked away from their deposits.

We're working to help resolve the issues, however, we have taken charge-offs and reserves to reflect current appraised values.

In the commercial real estate line of business we transferred $204 million in relationships over $2 million to non-accrual in the second quarter with the majority related to residential real estate development.

Slide 17 provides an overview of our consumer loan portfolio, which includes the consumer and residential mortgage loan categories on the balance sheet.

This portfolio is relatively small, representing just 9% of our total loans.

These loans are self-originated and are part of a full service relationship.

As expected, given the rising unemployment rate and falling housing values, we have seen some deterioration in our consumer portfolio, particularly within the home equity loan portfolio.

30 to 90 day delinquency rates are relatively stable; however the loss in the event of default has increased due to continuing falling home values.

We believe the issues remain manageable.

Slide 18 outlines the recent performance of the non-dealer automotive manufacture related portfolio.

We have reduced our loan outstandings by $1.4 billion or 52% since the end of 2005.

This portfolio now represents less than 3% of our total loans and we plan to continue to reduce our loans to the automotive sector.

A key component of charge-offs in the sector was the bankruptcy of GM, specifically the complete charge off of the leverage lease supported by two large stamping presses.

As a result of this charge off, we had no direct exposure to GM.

Excluding the GM lease, the performance of the portfolio continued to be good.

Non-accrual loans increased by $21 million at the end of the second quarter and remain manageable.

Net charge-offs excluding the GM lease remained at a lower level at $6 million.

Many of our customers who supply GM and/or Chrysler have been named essential suppliers and therefore will continue that offering.

Our auto dealer business is outlined on slide 19.

Average outstandings in this portfolio have declined $1.6 billion or 30% over the past year, in line with falling auto sales volume.

The dealer portfolio is well diversified with close to 80% of the portfolio with dealerships selling foreign nameplates.

Exposure to the single dealers of the Detroit Three is only about 5%, which is down from 10% at the end of the first quarter.

We continue to have excellent credit quality in this portfolio, with no non-accruals or charge-offs in the Second Quarter.

In fact, we have not had a significant loss in the dealer portfolio in many years.

Slide 20 provides further detail on the Chrysler and GM components of the dealer portfolio.

Our strategy for many years has been to work with top tier mega franchises which operate multiple dealerships.

Therefore, our exposure to single point Chrysler and GM dealers is very small.

We have seen no impact from the recently announced GM and Chrysler dealership closures.

Our exposure to the closed dealerships is minimal with only 11 customers among the 789 Chrysler dealers and 20 of the 1323 GM dealers.

Most of these dealers were part of larger dealer groups and will not be seriously impacted.

We expect the dealer portfolio will continue to perform well.

To conclude on credit, we conduct in depth reviews of all of our watch list credits at least quarterly to insure that we have an appropriate work out strategy as well as reserves and carrying values that reflect our collateral assessment.

We continue to obtain current appraisals on residential and commercial properties and take charge-offs that reflect the current value as well as reserves to reflect that values are expected to continue to decline.

We apply stress scenarios to the portfolio as we assess the adequacy of our credit reserves and we are comfortable with our current coverage.

We also review our reserves with our regulators and auditors every quarter.

Our outlook is for net credit related charge-offs in the third quarter to be similar to the second quarter and to improve modestly in the fourth quarter.

This is an increase from our prior outlook as the recessionary environment continues to impact our Michigan middle market customers and residential real estate values have yet to stabilize particularly in Florida.

We expect provision for credit losses will continue to exceed net charge-offs.

Now I'll turn the call back to Beth.

Thanks, Dale.

Turning to slide 21, our Tier 1 capital ratio is well in excess of the well capitalized threshold as defined by the regulators and it has increased over the past three quarters.

Turning to slide 22, and the tangible common equity ratio, we have maintained a solid capital structure with a large component of common equity for many many years.

Our tangible common equity ratio which was 7.55% at the end of the second quarter increased from the first quarter and historically has been well above the average ratio of our peer group.

Slide 23 updates our expectations for 2009.

The contracting economy is expected to result in subdued loan demand as has been the historic experience in every recession.

We believe that the net interest margin will continue to benefit improved loan pricing and maturities of higher cost funding.

Excess liquidity is expected to offset those benefits for the near term with the third quarter 2009 net interest margin expected to be relatively unchanged from the second quarter.

Excess liquidity is expected to diminish during the fourth quarter for maturities of wholesale funding resulting in net interest margin expansion.

The target federal funds and short-term LIBOR rates are expected to remain flat for the remainder of 2009.

Assuming there's no significant further deterioration of the economic environment, our outlook for net credit related charge-offs is for the third quarter to be similar to the Second quarter, and to improve modestly in the fourth quarter.

Provisions are expected to continue to exceed net charge-offs.

We expect to continue to sell mortgage backed government agency securities in order to realize gains.

Our goal is to maintain the size of the portfolio at about 10% of average assets.

Cost saving initiatives are expected to assist us in achieving a mid to high single digit decline in non-interest expenses from 2008 levels, despite increasing FDIC and pension costs.

This is an improvement from our previous outlook as a result of the success we have had in cutting costs.

We believe that our strong capital position, vigilance in managing credit and building reserves, as well as focus on controlling expenses, will assist us in managing through the current environment and position us well as the economy improves.

Now we would be happy to answer any questions you may have.

(Operator Instructions).

Your first question comes from the line of Matt O'Connor with Deutsche Bank.

Good morning Matt.

Very nice job by the way in the auto exposure.

I think a lot of people have been thinking there would be more fall out, that played out the way it did, so nice job there, but just in general as we think about where the credit stage is at this point, it seems like they're spreading to C & I in general, commercial real estate in general outside the residential construction, so I guess just trying to get a little more clarity on why you think losses essentially have peaked here, or may peak next quarter when it seems like maybe we're in the early stages of the more traditional commercial cycle.

My view on that is that while we think that -- I'll break it into a couple of components.

The residential real estate portfolio that we've been talking about in California continues to decline.

Loss rates continue to decline.

Reserve build there continues to decline ultimately.

Commercial Real Estate, primarily residential across the national market is obviously showing signs of deterioration, which we've seen in this quarter which we've seen in which we've seen in this quarter, which we've seen in the numbers, and we've begun to see some middle market particularly in Michigan deterioration.

While we've seen small business remain stable, Texas has remained stable, and frankly our Florida exposure, while it's jumped up in terms of problems, is not a particularly large exposure, Therefore, while we've seen a lot of residential charge-offs in the past we'll see that replaced by middle market, particularly Michigan charge-offs and a little more commercial charge-offs and we believe auto will continue to be a pretty good story including the dealer piece, so it's the composition and a little bit of the geography so I think we can maintain it assuming the economy doesn't deteriorate further, which is a big assumption I think in this environment.

I think that we're comfortable with our assessment of the next few quarters.

Okay.

And I imagine the severity is outside of residential construction will be a lot less?

Yes.

Because I think the real estate piece, clearly with the fall off in values has been more significant than anyone would have anticipated.

Right.

And then on the shared national credit I guess you get notification for what you lead in the second quarter and the third quarter you find out on all of the other deals basically?

Yes, where we age a credit we know those results and those would be reflective in the numbers and on those deals we don't agent, we proactively make phone calls to find out from the agent what the results of the shared national credit review has been, and in some cases the agent tells us before the formal report is issued, and in some cases they don't but when we know the action we adjust our numbers right then so anything we know is reflected in these numbers for the second quarter.

Final results will be probably some time in August.

And just lastly, assuming charge-offs were stable in Q3 and decline a bit in Q4, along with your guidance, how much reserve build should we expect from here?

Well, we haven't verified the amount but I think it's fair to say we'll continue to see reserve build, just similar from the last few quarters would be my guess.

All right, thank you very much.

Thanks, Matt.

Your next question comes from the line of Craig Siegenthaler with Credit Suisse.

Good morning Craig.

Thanks and good morning.

Just a few questions for Dale on credit.

First was looking at the pick up in net inflow of non-accruals and this was a trend going down for a few quarters.

I'm wondering was the delta similar to net charge off trends being the Midwest in Florida and geography in residential real estate and secondly do you think this quarter could be the peak in that net inflow?

On one of the slides, slide 16 where we break down the net loan charge-offs you can see where the charge-offs have been and the national developers and a little bit in Florida.

When you look at our inflows that we've seen, we've seen certainly real estate be the predominant inflow, about 49, 50% of the inflows are real estate this quarter, the rest is mix, I would certainly hope that we would start to see improvement in inflow in the next few quarters but it's a difficult environment to predict anything in our forecast, so it's difficult for me to answer that but I think the inflows that we have seen being predominantly real estate, until we see values stabilize a bit, new home starts for example, are up, they're up for four consecutive months particularly in California.

That's a positive, but whether that's a trend who knows, whether it affects all markets eventually I don't know when that happens so it's hard to call that but I would hope we would start to see some improvement but I can't call it.

Would the new home starts would actually be a negative as it brings new supply in the market?

Well yes and no, but I think what it indicates is people are in the market looking and buying, and it also means financing is becoming more available, so I think that it's a plus when the perspective of just the activity, people are out looking which means builders are out looking to create more homes and Yes, it creates more supply but frankly, I think at the end of the day, I view it as more of a positive than a negative.

And in California prices have stabilized.

The last four or five months in a row we've seen an increase month over month in prices.

That's a good indicator as well.

Which helps us on all of the other things we're doing there.

It also indicates confidence is building a bit, all points towards could we be bumping along the bottom now and beginning to firm up there.

Thanks, helpful.

Just a quick question on loan demand.

It seems like your come en tar it this morning was a little more cautious on loan demand than peers, just trying to reconcile if that's more a function of geography or your commercial loan focus which could be impacting your internal forecast here?

Well maybe a little geography.

Just in general if you look back at recessionary environments, it's difficult to see, historically, people just have a moral, if you look at the dealer business which we talked about car sales are down, dealer loans, therefore because of the preponderance of floor planning we do would naturally be down, no one is looking for the moment to make new commercial real estate development loans, there's a fair amount of excess capacity so that's going to be a negative and just in general I think the economy is still acting as a bit of a dampening.

There's a fair amount of excess capacity that will have to be soaked up but we'll start to see in my opinion any significant increase in loan demand.

People in businesses are still being very cautious.

They aren't stepping up to expand or increase earnings or capital investments at this point in time.

Great.

Thanks for taking my questions.

Thank you.

Your next question comes from the line of Steven Alexopoulos with JPMorgan.

Good morning Steven.

Good morning.

I guess my first questions are for Dale.

It looks like you had $83 million of charge-offs in the C & I business this quarter.

Now, within your guidance, are you assuming that is at a peak?

Are you assuming that continues to rise but there are offsets in other areas?

I think that we'll probably see C & I sort of bump along as its been in this quarter.

Obviously the buckets will change a bit, the geographies will change a bit.

Again, as we see less of a pinch from the residential real estate, the old portfolio one day I won't have to talk about anymore as we see less of an impact there that will be picked up a bit maybe in some commercial real estate loans, so when you look at the third quarter that we've talked about, it's probably fair to assume that the components won't look materially different than what we've seen in the second quarter.

It may shift a bit but I don't think a lot.

Just to clarify, it's $140 million.

The 83 you mentioned was first quarter.

It was $140 million excluding commercial real estate in the second quarter.

Right.

Commercial Real Estate was 108.

Looking at the Real Estate construction line, did you see any shift from residential related to commercial, because many banks are saying that and how does that build into your expectations?

We've seen very little of that.

We've seen a little, a handful of loans, three or four loans I think that were not purely residential but again it's predominantly residential and I think that it's certainly likely you'll see some of the commercial real estate projects that are not residential continue to be challenged whether that be retail or multi-family, both retail and multi-family are somewhat softer but so I think you're going to see a mix that will be a little bit more commercial real estate in some of the sectors.

Middle market, it's going to be sort of what we've seen here this quarter.

Small business I think will continue to be relatively stable.

We don't expect auto to raise up and be a particularly significant issue and obviously we don't think that's the case in dealer, so the mix is a little tough to call.

We worked residential in Michigan down substantially so residential in Michigan as an example isn't a major issue for us anymore but just the pieces of the pie are a little hard to forecast sometimes, so when you look at us talking on a third quarter that looks like the second quarter, I would say that generally speaking, the buckets will look fairly similar.

Maybe just one final one for Beth.

Should the lower level of tax expense continue now each quarter under this new methodology?

I think the way you should look at our taxes is to take whatever pre-tax results that you're kind of forecasting for us, apply a 35% tax rate to that and then factor in about $15 million a quarter of tax benefits from tax exempt low income housing tax credits, so that's how I would give you guidance on calculating our taxes.

Perfect.

Thanks.

Thank you.

Your next question comes from the line of David Rochester with FBR Capital Markets.

Hi, good morning guys.

Can you update us on the size of the watch list at this point and the amount of the early stage delinquencies in the second quarter?

Yes.

We've talked about it being up this quarter but to $7.4 billion it's up about I guess maybe $750 million.

If you look across the components of that and that's our special mention sort of non-accrual self-standard items, it's generally reflective of our overall portfolio.

That is to say you'll see migration primarily in middle market and real estate, middle market more so in Michigan than elsewhere, real estate generally speaking in most of the markets with Texas continuing to be pretty good without having a major impact, so while it's fair to say that our special mention and substandard buckets are still filling a bit, at least this quarter it slowed some and when you do the math, it's about 15.9% of our loans, so that will continue to be an issue that drives among other things our provision expense every quarter because obviously that's a key component of our calculations.

He asked about early stage as well, Dale, which we quoted.

The early stage if you just look at our sort of past dues from 30 to 89 days, it's $371 million and that's down from $495 million in the last quarter and over 90 is pretty stable and as we indicated that existed at March is largely gone, so we knew there's some inflow into the new 90 days this quarter.

They continue to churn.

They continue to take actions, and in this environment, since a fair amount of these would be real estate related, the restructurings take longer, they're more complex and so they just take longer to work through but they do all work through and we track all that.

Okay, thanks, and just one quick one and this is going to be a little difficult to answer.

As you're reappraising CRE collateral on problem loans, do you have a rough sense for how much those valuations are declining from the original appraisal value?

I know that's going to vary across product type but can you give us just a rough sense across your markets what you're seeing?

Well, the best indicator is about two years plus of the residential real estate stuff in California which started at just shy of $1 billion and is down now to between $300 million and $350 million and those values continue to decline and about every couple of quarters we get a new independent appraisal and the early hit was depending on what it was, and where it was located obviously would be 25 to 30% and the next one would be another 10 to 20% so I would say by and large right now, you would see marks that would be 50 to 60% over time on the residential component of the stuff we saw in California.

Commercial is too early but that won't be anywhere near what we saw in residential.

Commercial will be a lot less in terms of its severity based on just the early read of what we're seeing.

Okay, great.

Thanks for the color.

Thank you.

Your next question comes from the line of Brian Klock with KBW.

Hi, Brian.

Good morning.

Thanks for taking my call.

I think you answered most of my questions already.

I did have to jump off so I missed a discussion Dale and I apologize for this when you talked about the net charge-offs by market and on page 12 of the slide deck, the other markets what was the $45 million in second quarter, what was that related to?

That was mostly our national developers in various markets, as i think you know as part of our real estate line of business, we've got a portfolio of national developers that are doing construction lending across a range of markets and so what this would be would be loans to national developers that would be in a range of different markets.

There wasn't any one particular market where this would have been an issue and you're just seeing what we have seen in commercial real estate in general which is a deterioration in values and some projects just not being able to be completed on budget so that's what's really driving that.

And that relates to I guess the balances and commercial real estate line of business on slide 15, the 600 million?

Is that apples-to-apples?

It might.

Let me look at what you're talking about.

Yes, that does relate so that's part of that overall commercial Real Estate line of business, the 5.2 billion.

And Beth you talked about the security sales of $2.3 billion that were sold in the second quarter, the expectation that if you're going to bring the securities portfolio and maintain a 10% to assets level, I guess that implies today that there's another $1.1 billion or $1.2 billion that would be sold in the third quarter.

Now does that sound like what you're talking about earlier?

Well we haven't given specific guidance about gains that we might see for the balance of the year.

Obviously it's very dependent on the market, what's going on in the market.

As you saw in our slides, at June 30, we did have an unrealized gain of $142 million in the portfolio so there's still significant gain depending on market conditions.

Okay.

And I guess the guidance then would be though if you were to pull those securities off the balance sheet the margin would be stable from the second quarter?

The guidance we gave factored in potential security sales for the balance of the year, so the margin guidance incorporates our estimate of that.

Okay, great.

Thanks for taking my questions.

Thank you.

Your next question comes from the line of Brian Foran with Goldman Sachs.

Hi, Brian.

Good morning.

I'm sorry if I missed this but the shared national credit there was a reference in the slides to stress in the residential real estate portion of shared national credit.

Can you just remind us how big that exposure is and any description around property types and location?

Yes.

Well, it's fundamentally, before I tell you that, the shared national credit portfolio is in fact very reflective of what we're seeing in the rest of the book, so what you're seeing in fact is the same sort of trends and NPLs and charge-offs.

When you look at the commercial real estate component of what we've got, it's a couple billion dollars as of the end of June within our SNIK book.

Okay?

Your next question comes from the line of Mike Mayo with CLSA.

Hi, Mike.

So the loan losses are a lot worse than your prior guidance, or I guess you kind of said that, but the economy is a lot worse so I can understand some of that but what was really the trigger or what's the big delta between what you thought before, and what you reported this quarter and expect the rest of the year?

It seems like it's the appraisals and what was the trigger for having new appraisals or can you just talk about the difference?

Sure.

There's a few deltas.

One would be, I referenced in particular Florida.

As we've said, and as we pointed out in the slide, we don't have a lot of land in Florida.

That's good.

We don't have a lot of single family because we managed it down so we got a couple hundred million of condo loans.

Those loans are all, they take two to three years to build and deliver, so those are all coming on stream.

All those have had deposit, well most have had significant deposits and so forth, meaning people are bike them and have bought them.

The problem is one, values fell rather substantially and these tend to be non-conforming and today in this environment people are having a hard time getting those things financed so your typical issues are on construction risk.

The construction risk really on these condos isn't there anymore but it's getting these things actually sold and closed into a mortgage so that's part of it.

We referenced this GM lease, frankly, there's a couple of stamping presses.

We had expected those would continue to be used and by the way they are, and we expected the senior debt to be paid and the leverage lease to basically work through its normal course.

We were a little surprised I guess that that isn't the case, that they are going to redo those so that was a piece of it, and just in general as you said earlier, Mike the economy is worse so it's impacted the middle market particularly in Michigan more than we thought.

Clearly not as much in the auto space, which is good.

Clearly not in the dealer space, but just in general in some other companies, so in kind of, and those pieces if you will if you look at where it is, and obviously commercial Real Estate in general is reflective of soft values continuing to be out there.

Do you think your reserve to NPA ratio and you said it's not completely apples to apples comparison but do you really think you have enough reserves for these problems you're seeing ahead?

Compared to several decade history of Comerica, this is so far off the chart and it seems like all the guidance is increasingly more negative, why not just increase the reserves to a level that's more like 80% of NPAs?

Well the answer is yes, we think it's quite adequate.

One of the reasons we think that is it's been charged down by 39% and if you look at the trends, frankly each quarter over the last I don't know, two or three that's continued to be charged down even more.

In addition to that we've got reserves that sit on top of that, so we think, and to have a level of charge-offs this quarter and then provide another 60 million on top of that after several quarters of providing on top of that and building the coverage of just on loans, we think it's definitely appropriate and not only do we think it but we share it with regulators and auditors and a whole cast of folks who I think feel comfortable with what we're doing and in response to the last piece, I know I'm going to be redundant with you but it's the same process we've used for quite some time and we can't just go out there and decide well, we're just going to plug a number in and that's going to be it because you need a process, you need to stick to it, it needs to be consistent and well documented, all in which our case are true.

So if it's charged down by 39%, can you give us any context for comparing that charge off level to maybe where the industry is or that kind of stands out there and how do we know that's right looking in from the outside?

Well, I don't know what others have charged their loans down to and in some cases I'm not sure whether they know or not either so I don't know how you necessarily compare that number.

All I know is that when we, the process for us is very well defined.

When you look at the amount of writedown and provision we've taken on top of what we've got, Mike, and you look at the discipline around the process and the number of people that look at it, I feel good about what we do and where we have it, so beyond that, the key pieces is the mark and the other thing and I know you've heard me say this before, is we're not much of a consumer or retail bank.

You know that those that are have different looking numbers and you'll charge as do we consumer down right when it hits the wall at about 180 days.

In commercial it's a different game and you tend to carry them longer and you work them harder and longer so it's just a different environment.

And I think Mike if you've listened to recent conference call, not a lot of banks disclose this number.

We have for many years disclosed this charge down number and second at least based on information I've seen in transcripts there are other banks who have disclosed it they aren't nearly as marked down as ours.

All right, thank you.

Thanks, Mike.

Your next question comes from the line of Chris Mutascio with Stifel Nicolaus.

Good morning, Ralph, Beth, and Dale.

I appreciate you taking my question.

Hi, Chris.

I think Mike was piggybacking on his question but I think you answered that in terms of why the guidance is up somewhat substantially from three months ago in terms of the charge-offs but let me ask it a different way and I don't want but let me ask it a different way and I don't want you to take this the wrong way but I'm trying to reconcile the thought process on the call about maybe we're reaching a bottom on credit, when I'm seeing at least from a quarter perspective an acceleration of the NPA growth, both in terms of percentage and dollar amount and also in conjunction with the net charge off guidance that from my calculations it looks like it might be about 30% from the guidance just three months ago so how do I reconcile the tone of maybe we're bottoming when it looks like the numbers posted in the quarter seem to be a bit worse if not more significantly worse than what we thought just back in April?

Well, I think again that a couple answers, whether we're at the bottom or not I don't know if we're necessarily there.

If we are at the bottom we'll continue to bump along for a while.

If you look at the inflow to non-accruals this quarter again, mostly real estate and you look at the rest of it, but these are let's pick the half that's not real estate for a second.

Those are generally very well secured transactions that we're in the process of working through that I think by and large the marks, the loss severity will be a lot less than we've seen in certainly residential real estate so I think the mix going from residential to other and even the mix going from residential to commercial, the loss severity is a lot less.

It looks a lot better, particularly let's say on the middle market side so that would be one part of the answer.

I think that if you see that I hate to keep being redundant but the fact that we've written it down substantially, so $0.39 which is down further than we had it last quarter, it was $0.36 last quarter, so you look at all of that and you look at the fact that we're still building reserves at this time and if you believe any of the economic forecasts that maybe the fourth quarter starts to look a little better, I think we're okay in terms of the way we have the numbers pegged.

If the economy gets worse, if things still continue to decline, then I think we're going to be back revisiting that, but based on what we're seeing on those things that I mentioned I think that it's the mix amount of accrual as much as anything that drives me to that conclusion.

As always thank you for the color.

Thanks.

Your next question comes from the line of Jeff Davis with FTN Equity Capital.

Good morning.

Two part question.

One, if you could comment on the energy book with oil prices I guess being volatile and then natural gas prices being soft throughout the year, maybe longer, and then secondly, in terms of your ability to monetize problem assets either foreclosed property or selling the notes what's the appetite among distressed investors?

Is there any stepping up to the plate?

Thank you.

Sure.

The energy book is about $1.6 billion.

We've had very little issues.

It's been well managed.

There's always one or two things here or there but it's not been significant.

Most if not all of our customers are active hedgers which helps enormously.

If you look at the mix of our product, it's more natural gas than it would be oil, which is another piece of the pie.

If you look at the fact that we have our own engineers on staff that do independent engineering studies which are in essence energy appraisals, that helps us a lot in terms of getting comfortable and if you look at the whole process we utilize from the setting price decks we meet every month, used to be every couple of quarters on price deck issues, I feel comfortable that we're on top of it, that we're dealing with those sort of mid range companies not the mom and pops, not the big guys, and if you look at the controls and the process I think it's rock solid, so will there be problems from time to time, sure.

We're seeing a few here and there but nothing material.

In terms of the secondary market we are seeing more of an appetite and in fact in this last quarter while it wasn't a ton we sold four loans that was about $16 million and actually did pretty well vis-a-vis what we charged them to and what our reserves were.

We are clearly seeing increased activity in secondary market.

We're actively looking at some things right now.

We've in fact sold a couple loans already, and I think that will be good.

It's been positive in terms of that, so I think there's more activity and we certainly will monitor it and take advantage of it when it's appropriate.

Your next question comes from the line of Ken Usdin with Banc of America Securities.

Hi, Ken.

Two quick questions.

First of all, within the charge-offs, can you just give us a feel of how granular the charge-offs were?

Meaning did you have anything really bulky this quarter and as far as how you see things playing out over the next couple quarters, are you expecting it, do you have any big lumpy losses coming through or is this kind of a real granular through the portfolio?

The only lumpiness this quarter was in that GM lease which was almost $21 million.

Other than that, if you looked at the charge-offs for us, it was fairly well diversified in terms of not only line of business but in terms of kind of the average size of the deal, so that GM piece was obviously the biggest piece that we really had to deal within the current quarter.

And you never know, I mean there's always surprises that you hopefully are guarding against, but I would, historically, frankly we've avoided typically the large bulky kind of hits but from time to time, some things pop-up that you got to deal with, but so generally other than the GM piece, I would say it was pretty well managed and reasonably granular.

My second quick one is just on the margin outlook.

Maybe it's for Beth.

In terms of walking through the flat margin expectation for the third quarter, can you just talk us through the pluses and minuses, meaning why flat, why won't you see a little bit more improvement?

Aside from the excess liquidity, which is kind of I think that's run rated by this point can you just walk us through the moving parts of the margin?

Yes.

We'll continue to see in the third quarter improving loan spreads is our expectation.

That was a significant contributor in the second quarter.

We will also see the maturity of some higher cost wholesale funding in the third quarter, so those are all positives that will continue in the third but it will be offset entirely by this excess liquidity, which by the way, is significantly higher in the third than the second.

If you just take a snapshot and look at our balance sheet, on average we had a billion eight on deposit with the Fed in excess liquidity in the second quarter, but by the end of the quarter, that was $3.5 billion and in addition we have about 800 in addition to that of just very short-term liquidity so we had 4.3 billion at June 30 compared with the $1.8 billion on average for the quarter, and that's why there will be a bigger impact of excess liquidity offsetting those other positives that we see, so we assume with wholesale funding maturities toward the end of the third quarter and into the fourth quarter that that excess liquidity will dissipate and we'll see the margin expansion continue.

So that should be a pretty, I don't know how to define meaningful but that should be a pretty decent number of improvement once we get into the fourth quarter?

That's correct assuming the excess liquidity dissipates as we expect.

Okay, great.

Thanks a lot.

Thanks, Ken.

Your next question comes from the line of Gary Tenner with Soleil Securities.

Good morning.

Thanks everybody.

Good morning.

I had two quick questions.

First off, on the carrying values of the NPLs.

Can you tell us what amount of the $1.1 billion are actually carried at an impaired value as opposed to the ones that are carried with a specific reserve against them?

Well, all of them carry a mix of reserves whether they are sort of standard reserves or individual reserves, they all carry their loan if you will individual reserve against them, so when we quoted $0.39 that's looking at the writedowns obviously down to that level with reserves over and above that, so I can't go and say how much above that in terms of the numbers we've quoted in terms of NPA coverage and total reserves against loans.

It's credit by credit.

So it's not, we look at each one being I mean they all have their own individual reserves after they've been charged down.

And just Beth on that mention of the wholesale funding maturities, in late Q3 and Q4, can you give us a dollar amount of what's coming due?

We have $5.8 billion maturing between the end of June and the end of December and of that, $2.3 billion is senior debt.

Most debt matures actually in September.

The other $3.5 billion is CDs, mostly retail brokerage CDs, and about $2.5 billion of that $3.5 billion carry rates above 3% so that's why those will be very nice to see mature.

Okay, great.

Thank you.

Thank you.

Your next question comes from the line of Terry McEvoy with Oppenheimer.

Hi, Terry.

Terry, your line is open.

(technical issues) -- and then you also have an in house economist who does a region by region analysis and review.

Have you combined both the historical perspective plus with the outlook to try and get a feel for when you think demand will pick up within your Markets for Comerica?

Terry we didn't hear the first part of your question.

If you could repeat that?

Sure.

I wanted to talk about loan demand and I know you've done a lot of work based on past economic cycles and how that's impacted demand among your borrowers and so have you combined your historical work with your in house economist outlook for the regions in which Comerica operates, and does that give you a feel at all for when you think demand for Comerica for credit is going to increase?

I haven't looked specifically at that obviously we pay a lot of attention to Dana's forecast and I'm sure Beth will have something to say on this but I would say that a couple of things in my mind have to occur.

Some of this excess capacity is going to need to be utilized.

Typically when we see loan demand it's for capital investment purposes when we see the ability to move new relationships and so forth and the other piece of course related to that is the build of inventories.

Inventories continue to decline and we think there's pent-up demand that as this economy turns, not only the need for cap it tax investment but the need for working capital support will be there, so I think that may be a quarter or two away, we'll see, based on what Dana is saying, so I'm hopeful that by the fourth quarter we might start to see some of that happen but it's a little early to say at this point.

If you look at historic modeling that we've done, certainly there's a bit of a lag between when the economy begins to come back and when we see C & I growth, so there's a lag effect, and that has to do with confidence that the economy has reached bottom and is finding a good framework to move forward, so to me, the hinge in all of this is the confidence of the businesses to be investing, so I think there's typically a lag effect.

At this juncture, we see the economy beginning to move in a positive manner as Dale mentioned in the fourth quarter.

Dana's current forecasts I believe, he kind of thinks the bottom is in the fourth quarter and will start up there but we'll start up gradually, and it will take some time as Beth said for confidence to build and the businesses start to build inventories again and we likely will have double digit unemployment at the same time, which is a lagging indicator, which probably will not start down until probably mid year next year, so I think you're going to see a bit of a U here as things come out versus the old time V of coming out very quickly.

Appreciate it, thank you.

Ladies and Gentlemen, we have reached the allotted time for the Q & A session.

I'll now turn the call back over to Ralph Babb.

Thank you very much for being with us today.

We appreciate your interest as always in Comerica.

Thank you.

Ladies and gentlemen, this concludes today's Comerica second quarter 2009 earnings conference call.

You may now disconnect.