Comerica Inc (CMA) 2010 Q1 法說會逐字稿

Good morning.

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

At this time, I would like to welcome everyone to the Comerica first quarter 2010 earnings 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 begin your conference.

Thank you.

Good morning, and welcome to Comerica's first quarter 2010 earnings conference call.

Participating on this call will be our Chairman, Ralph Babb, our Chief Financial Officer, Beth Acton, and our Chief Credit Officer, John Killian, and Dale Greene, Executive Vice President of the Business Bank.

A copy of our press release and presentation slides are available on the SEC website as well as in the Investor Relations section of 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 expectations.

Forward-looking statements speak only as of the date of this presentation and we undertake no obligation to update any forward-looking statements.

I refer you to the Safe Harbor statement contained in the release issued today, as well as slide two of this presentation which I incorporate into this call.

As well as our filings with the SEC.

Also, this conference call will reference non-GAAP financial measures and in that regard I would direct you to the reconciliation of these measures within this presentation.

Now, I'll turn the call over to Ralph.

Good morning.

The encouraging signs we saw in the fourth quarter of 2009 continued into the first quarter of 2010.

Our credit quality improved at a faster pace than we expected, reflecting the strong credit underwriting and processes we have in place.

Our net interest margin continued to expand.

These and other positive developments resulted in our first quarter net income of $52 million, the equivalent of $0.33 per share.

This included a $17 million aftertax gain, equivalent to $0.11 per share related to the cash settlement of a note receivable associated with the 2006 sale of an investment advisory subsidiary.

The negative impact to earnings of the $2.25 billion of preferred stock issued to the US Treasury under its capital purchase program, fully redeemed in March, was $123 million, or $0.79 per share.

Our customers continued to convey a more positive and upbeat tone.

This is reflected in our loan pipeline, which has now grown to its highest level in two years.

The small business loan pipeline in our Texas and Western markets has increased by double digits in the last three months.

Now that credit is improving, our bankers can devote more time to marketing.

In Texas we are seeing more opportunities and plan to add several new middle market and small business bankers to capitalize on them.

In California, customers and prospects are seeing gradual increases in sales and are more optimistic about their businesses as backlogs are growing.

This has led to more loan proposals, particularly for middle market and technology and life sciences companies.

In the Western market, we have 61% of our national dealer services business, floor plan loans are slowly picking up as expected with the increase in auto sales.

In Michigan, we had more new and expanded loans approved in middle market this March than we've had in any month since 2008.

As you know, middle market is one of our sweet spots.

Our relationship managers are known for their ingenuity, flexibility, responsiveness and attention to detail.

We stand out from competition because of our experience, expertise and long-standing commitments to our customers through all economic cycles, including the current one.

It is not something that is replicated overnight.

New and renewed loan commitments for our bank as a whole totaled $6 billion in the first quarter.

We are ideally positioned to develop new relationships and expand existing ones as the economy continues its recovery.

The decline in loan outstandings we saw in the fourth quarter of 2009 slowed in the first quarter of 2010, and the pace of decline moderated in each successive month of the first quarter.

Average loan outstandings increased modestly in national dealer services.

Core deposit growth continued in the first quarter, but at a slower pace.

In certain business lines, deposits have decreased, which we believe is a positive sign that customers are starting to use their cash in their businesses.

We are pleased with the continued broad-based improvements in credit quality, including significant declines in net charge-offs and provision for loan losses.

These positive improvements are the result of our focused efforts to quickly and proactively identify and work through problem loans.

We saw improvement in credit quality across all business lines.

Net credit related charge-offs decreased $52 million in the first quarter, led by a significant decline in commercial net charge-offs.

The commercial real estate business line experienced an increase in net charge-offs, but saw declines in non-accrual and watch list loans.

Non-performing assets decreased $41 million, and the provision for credit losses decreased $77 million.

Non-accrual loans were charged down 44% as of March 31, the same as December 31, 2009.

Our watch list loans were down $228 million.

We continued to diligently manage credit throughout this economic cycle.

The net interest margin increased 24 basis points to 3.18% in the first quarter, primarily from improved loan spreads, a less costly blend of core deposits and maturing higher cost wholesale funding.

Excluding the impact of excess liquidity, the net interest margin would have been 3.42%.

We continue to focus on expense controls.

Non-interest expenses decreased $21 million from the fourth quarter.

Full-time equivalent staff decreased 481 employees or 5% from March 31, 2009.

Our capital position remains strong.

Our Tier 1 capital ratio is estimated to be 10.4% at March 31.

In addition, the quality of our capital remains solid, as evidenced by a tangible common equity ratio of 9.68%.

Together with our strong liquidity, we are ideally positioned for future growth.

On March 17th, we fully redeemed the $2.25 billion of preferred stock held by the US Treasury under its capital purchase program, five days after completing the public issuance of $880 million of common stock.

Our participation in the capital purchase program helped stabilize the country's financial system at a critical point, and the investment the government made in Comerica resulted in excellent returns for US taxpayers.

We elected not to repurchase the related warrant from the US Treasury, as we believe it is best to retain capital for future growth.

The warrant allows the holder to purchase 11.5 million shares at an exercise price of $29.40 per share.

Given the present market price for Comerica common stock, the warrant has significant value.

In closing, we believe we are on the path to normalized earnings with great opportunities to develop new relationships and expand existing ones.

We have a consistent strategy for success that is based on relationships with a main street banking focus.

Based on all of the positive trends we are seeing, we expect our operating fundamentals will continue to show improvement in 2010.

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

Thank you, Ralph.

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

Turning to slide three, we outline the major components of our first quarter results, compared to the prior period, and the same period a year ago.

Today, we reported first quarter 2010 net income of $52 million.

This included $17 million from Discontinued Operations, reflecting the cash settlement of a note receivable related to the 2006 sale of Munder, our former investment advisory subsidiary.

After preferred dividends, the US Treasury of $123 million or $0.79 per share, the net loss attributable to common shares was $71 million, or $0.46 per diluted share.

I'll describe the preferred stock redemption further in a moment.

In the first quarter of 2010, before preferred dividends, continuing operations were profitable, both on a pretax basis as well as aftertax.

Slide four provides highlights of the financial results for the first quarter compared to the fourth quarter.

Credit quality metrics continued to improve.

Net credit related charge-offs decreased by $52 million from the fourth quarter, to $173 million.

The provision for credit losses was $182 million, $77 million less than the fourth quarter.

Non-performing assets declined $41 million, and the inflow to non-accrual slowed by $21 million to $245 million.

The net interest margin in the first quarter increased 24 basis points to 3.18%.

Maturing higher cost funding and improved loan spreads contributed to the increase.

The low return on excess liquidity had a 24 basis point negative impact, which I'll describe in more detail in a moment.

We continue to carefully control expenses.

Non-interest expenses decreased 5%, and included a decrease in salaries and benefits as well as lower ORE costs.

We fully redeemed $2.25 billion of preferred stock issued to the US Treasury after successfully completing an $880 million common stock offering.

Our capital position remains strong, as evidenced by our tangible common equity ratio of 9.68%.

Turning to slide five, I'll review the details of the redemption of the $2.25 billion of preferred stock, which was issued to the US Treasury under its capital purchase program.

On March 12th, we completed the issuance of $880 million of common stock, and the net proceeds, along with available cash at the holding Company, fully redeemed the preferred stock on March 17th.

In the first quarter, in addition to the $24 million quarterly cash dividend, and the $5 million non-cash accretion of the discount on the preferred stock, we also incurred a one-time $94 million non-cash redemption charge, reflecting the accelerating accretion of the remaining discount for a total impact of $0.79 per share.

We have elected not to repurchase the warrant that was issued in conjunction with the preferred stock in order to preserve capital in support of future growth.

On April 12th, the US Treasury announced it intends to auction the warrants of Comerica, as well as other banks in the course of the next several weeks.

The pace at which average loans declined continued to slow throughout the first quarter, as shown on slide six.

Average loans declined $1.4 billion in the first quarter, compared to the $2 billion decline in the fourth quarter.

This pattern of reduced demand is consistent with historical post-recessionary environments.

Our customers are feeling more confident about the economic recovery and we're seeing our loan pipelines grow.

We expect middle market and small businesses will start borrowing as their working capital needs, increase in line with economic growth.

Regarding FAS 166 and 167, both accounting standards were adopted as of January 1st, and the effect was not significant.

No additional entities were consolidated as a result of the new accounting guidance.

Turning to slide seven.

Our loan portfolio is well diversified among many lines of business and geographies.

National dealer services average outstandings increased modestly in the first quarter.

Decreased average outstandings in the first quarter were noted in a number of areas, with the largest declines in middle market, commercial real estate and global corporate banking.

Line utilization was 45.2% in the first quarter, down from 46.8% in the fourth quarter, and stabilized in the last month of the quarter.

As shown on slide eight, core deposit growth continued in the first quarter, but at a slower rate than recent quarters.

We had growth in Texas and Florida markets and most commercial lines of business.

Average core deposits increased $494 million, including a $942 million increase in money market and now deposits and $194 million increase in non-interest bearing deposits.

This was partially offset by a $650 million decrease in higher cost customer CDs.

Modest declines were noted in small business in all of our markets, as well as middle market in the Midwest and Western markets.

We believe this is a positive sign, that customers are starting to use their cash in their businesses.

As outlined on slide nine, the net interest margin increased 24 basis points in the first quarter, to 3.18%.

Without the 24 basis point negative impact from excess liquidity, the net margin would have been 3.42% in the first quarter, an increase of 35 basis points from the fourth quarter.

The increase in the margin was driven primarily by continued loan spread expansion, a less costly blend of core deposits and maturities of higher cost wholesale funding.

Excess liquidity was represented by an average of $4.1 billion deposited with the Federal Reserve in the first quarter, up from an average $2.5 billion in the fourth quarter.

Maturities of wholesale funding and expected loan growth will assist in dissipating excess liquidity.

This excess liquidity is above and beyond the investment securities portfolio, which will continue to provide a reservoir of liquidity.

Turning to slide ten, non-interest expenses decreased 5% in the first quarter.

Our largest expense item is salaries, and, therefore, management of staff levels is key.

As you can see on this slide, we have consistently reduced personnel over the past several years, even while we were opening new banking centers.

Our workforce decreased by approximately 5% from year-ago levels.

Salary and employee benefits expense was down 6% from the first quarter of last year.

In addition, ORE expense declined by $10 million in the first quarter, compared to the fourth quarter, and we continued to tightly control discretionary expenses.

Now, John Killian, our Chief Credit Officer, will discuss credit quality starting on slide 11.

Good morning.

The broad-based improvement in our credit metrics that we saw in the fourth quarter continued in the first quarter, and improved at a faster pace than we expected.

Net credit related charge-offs and the provision for credit losses improved significantly from fourth quarter levels.

Net credit related charge-offs were $173 million in the first quarter, a $52 million reduction from the fourth quarter, led by a significant decline in commercial net charge-offs.

Commercial net charge-offs of $42 million or 80 basis points have not been at this level since the third quarter of 2008.

Provision for credit losses of $182 million was $77 million less than the fourth quarter.

The provision exceeded net credit related charge-offs by $9 million, compared to $34 million in the fourth quarter, reflecting the improvement in overall credit performance.

The allowance for loan losses was 2.42% of total loans, an increase of 8 basis points from the fourth quarter.

The allowance for loan losses was 85% of non-performing loans.

Turning to slide 12, total non-performing assets declined $41 million to $1.25 billion.

Importantly, the inflow to nonperforming assets decreased by $21 million in the first quarter.

This marks the third consecutive quarter of decline.

Foreclosed properties declined $22 million to $89 million.

Loans past due 90 days or more and still accruing declined $18 million to $83 million.

Our watch list loans decreased by $228 million to $7.5 billion at the end of the first quarter.

This is the second consecutive quarter of decline, and reflects improvements in our portfolio in all geographic markets and across virtually all lines of business.

Slide 13 provides detail on the declining trend in net loan charge-offs.

Total net loan charge-offs declined $51 million to $173 million.

The decline can be attributed primarily to middle market, which declined $37 million, or almost 50% from last quarter, to $39 million, and global corporate banking, which was down $24 million to only $2 million in net charge-offs in the first quarter.

Net loan charge-offs in the commercial real estate business in the first quarter 2010 increased to $86 million from $62 million in the fourth quarter of 2009.

We expect that we will continue to see some variability here, with an overall downward trend.

Net charge-offs declined $42 million in the Midwest market and $21 million in the Western market, while we saw a $12 million increase in Texas, primarily as a result of charges taken on two commercial real estate projects.

On slide 14, we provide information on the makeup of non-accrual loans.

The largest portion of the non-accrual loans continues to be the commercial real estate line of business, which decreased $16 million in the quarter.

Non-accruals also decreased in global corporate banking by $30 million, and middle market by $7 million.

During the first quarter, $245 million of loan relationships greater than $2 million were transferred to non-accrual status, a reduction of $21 million from the fourth quarter.

Of these inflows, commercial real estate contributed $129 million.

Global corporate banking had no inflows to non-accrual greater than $2 million, compared to $42 million last quarter.

Middle market had $63 million, down $21 million from the fourth quarter.

Also, inflows decreased modestly in several lines of business, such as small business.

We sold $44 million of non-performing loans in the quarter, as well as $12 million in performing loans, and several short sales, whereby we settle a note with the borrower at less than par.

In total, prices approximated our carrying value plus reserves.

This continues to support our analysis of valuations.

On slide 15, we provide a detailed breakdown by geography and project type of our commercial and real estate line of business, which declined $191 million from the fourth quarter.

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

Total outstanding of $4.6 billion were down $749 million from a year ago.

This included a $472 million decrease in the Western market, $190 million decrease in Florida, and a $139 million decline in Michigan.

Slide 16 provides net charge-offs for our commercial real estate line of business by project type and geography.

Residential real estate development loan charge-offs remained at similar levels as the fourth quarter.

We have seen prices for single family homes stabilize and even increase in select areas.

However, land prices remain soft and in some locations continue to decline.

Charge-offs in the nonresidential real estate construction segment increased in the first quarter.

While we continue to see softness, we believe that nonresidential real estate will see far fewer defaults and much lower loss content than the residential construction segment.

While net charge-offs for commercial real estate increased in the first quarter in comparison with the fourth quarter, they remain well below the peak in the second quarter of last year.

Inflows to non-accrual increased to $129 million, compared to $64 million in the fourth quarter, but well below the peak last year of $211 million in the third quarter.

Commercial real estate non-accrual and watch list loans declined in the first quarter, and this, along with our analysis of migration patterns for the last several quarters, all supports our belief that negative migration is receding.

As shown on slide 17, as of the end of the first quarter, we reduced residential real estate development exposure by $1.3 billion, or 58% since June of 2008, to $964 million at March 31st, 2010.

Total single family construction outstandings were down $844 million or 64% from June 2008.

There are additional slides in the appendix which provide further detail on certain segments.

The consumer portfolio, representing approximately 10% of our total loans, continues to perform relatively well.

Slides detailing our auto dealer and automotive supplier portfolio also can be found in the appendix.

Both portfolios continue to perform as expected.

As far as the auto supplier portfolio is concerned, loan outstandings now represent less than 2.5% of our total loans.

Non-accrual loans continue to decline in the first quarter.

The auto dealer average outstandings have declined $815 million or 20% over the past year, in line with falling sales volumes of new cars.

We continue to have excellent credit quality in this portfolio.

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

This proactive strategy has resulted in a current carrying value of non-performing loans of 56%.

We are pleased with the improvement in credit metrics in the first quarter.

These results, as well as the positive trends we have seen and macroeconomic statistics, support our updated outlook for net credit related charge-offs of $675 million to $725 million for the full year 2010, which is a $100 million decrease from our previous outlook.

We expect the provision for credit losses will be consistent with net charge-offs for the year.

Now I'll turn the call back to Beth.

Thanks, John.

Turning to slide 18 in our capital ratios.

Our capital position is strong and historically, we've had some of the highest capital ratios in our peer group.

We have maintained a solid capital structure with a large component of common equity for many years.

Slide 19 provides an update on our outlook for 2010 which is based on a modestly improving economic environment.

We expect subdued loan demand for a while longer, as loan growth typically lags other positive economic indicators.

We expect that C&I borrowings will grow as working capital needs increase and will be partially offset by declining commercial real estate outstandings.

As a result, we believe we will achieve low single digit loan growth from March 31st period end to December 31st period end.

We expect the securities portfolio to remain at the current level.

Based on the assumption there will not be an increase in the Fed funds rate in 2010, we expect the net interest margin of 3.25 to 3.35.

This is a 10 basis point increase from our prior outlook of 3.15 to 3.25.

While excess liquidity has not dissipated as quickly as we expected, loan spread expansion and the level of non-interest bearing deposits have exceeded our expectations.

Our outlook is for net credit related charge-offs of $675 million to $725 million.

Provision is expected to be consistent with net charge-offs.

As John mentioned, there is $100 million decline from our prior outlook as a result of the positive trends we are seeing in both the economic environment and our credit metrics.

Non-interest income excluding 2009 securities gains is expected to be flat to a low single digit decrease, as we believe retail service charges on deposit accounts and market related fees such as brokerage and fiduciary will continue to be impacted by the cautious behavior of our customers.

The expected reduction of pension, FDIC, and ORE expense, as well as the continued careful control of discretionary costs, is expected to result in a low single digit decrease in expenses.

Overall, the many positive trends that continued in the first quarter, such as improved credit metrics, a slower pace of decline in loan demand, and a significant increase in the net margin, lead us to believe we will continue to see improvement in our core operating fundamentals in 2010.

Now, we'd be happy to answer any questions you have.

(Operator Instructions).

We'll pause for just a moment to compile the Q&A roster.

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

Hi, Steve.

Good morning, everyone.

Good morning.

I want to start -- you provided I guess $2 million above net charge-offs in the quarter which I guess would qualify as slightly above charge-offs.

I'm just curious, compared to a lot of your peers which are now guiding to reserve releases in 2010, why do you guys assume provision above net charge-offs for the full year?

The total provision of on-balance sheet and off-balance sheet is $9 million, in excess of total charge-offs, and I think we're just taking a conservative look for the rest of the year.

As you know, we have a rigorous process for determining the reserves and we're comfortable with the guidance that the provision will be consistent with charge-offs for the rest of the year overall, and we'll continue to monitor that very closely.

So perhaps releasing reserves toward the end of the year?

That's a possibility.

But we'll continue to watch it real closely, as you know.

Okay.

John, I know you break out the inflows into non-accrual for large credits but could you give what the total inflows were into NPA for the quarter?

Yes, they were $245 million, down $21 million from the 266 total in the fourth quarter.

Okay.

And finally, just one question on capital.

Now that you're profitable on an operating basis at least and sitting on almost 10% Tier 1, can you talk about expectations for increasing the dividend here and maybe potential timing?

I think, Steve, we'll continue to watch the economy and the improvement in the economy, as well as the improvement in our core operating earnings and we will monitor that along the way and make a decision at the appropriate time as to when we will recommend increasing the dividend.

Do you expect that sometime in 2010, Ralph, that you might recommend an increase in the dividend, though?

I really wouldn't put a time frame on it right now, because of the uncertainty of where the economy is going.

And as we watch that, we will closely monitor that.

Okay.

Thanks.

Thank you.

Your next question comes from the line of Ken Zerbe of Morgan Stanley.

Hi, Ken.

Hi.

Good morning.

Good morning.

Also another question here on capital.

When you think out a couple years about potential loan growth on an organic basis, possibly acquisitions, and I guess is there enough opportunity out there to actually redeploy your capital without doing things such as buybacks?

Or, you know, again, once the economy starts to improve a little bit more, are buybacks sort of a core part of your capital redeployment strategy?

Well, we've certainly been active in buybacks in the past, but as I was talking about earlier, we'll be watching the internal capital generation as it relates to the asset growth that we have and the opportunities that we have out there.

Certainly, acquisitions are one.

The economy is the other and waiting to see how quickly it will pick up as we mentioned in various of the comments today, we're starting to see signs that we think borrowing will start to pick up in the not too distant future, if the economy continues to stabilize and grow.

And Ken, I would add also that it's still very unclear from a regulatory standpoint for the industry, where the capital targets are going to be.

So until those are a little more clarity, we're being cautious in how we're managing the balance sheet, hence the decision for instance that we made to not repurchase the warrant as an example.

Okay.

And then the other question I had was just on the NIM.

I was a little surprised the NIM improved as much as it did, while you also had an increase in excess liquidity.

Could you just talk about the opportunity to increase NIM further from here, if you don't get a reduction in excess liquidity?

Well, first, we believe we will have a reduction in excess liquidity.

We do have $2.4 billion of debt maturities between now and the end of the year.

In addition, as we have mentioned, we do expect some modest amount of loan growth, particularly summertime through the end of the year.

So a combination of those will certainly reduce the excess liquidity and certainly to levels below where it was last year on average.

So I think we're comfortable that we will see a participation.

But you're right, the pace of it is -- we've made an assumption that it will dissipate largely through by the end of the year in our margin outlook.

And as you saw, we did increase our outlook for NIM by 10 basis points, really driven by very good loan spread situation and higher deposit levels than we were expecting.

So that is a positive thing.

When you think about the guidance we gave you and you pick the midpoint of that guidance, for the rest of the year we would have to average about 334 for the NIM to work out to that guidance we gave you.

So we certainly are expecting further improvements, part of which is also helped by, we have about $650 million of retail brokered CDs maturing in the second quarter which have a yield over 4%.

So we're positive about where the NIM is heading, as evidenced by the improvement in the outlook we gave.

All right.

Thank you.

Thank you.

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

Hi, David.

Thanks for taking my questions.

So you had just touched on those institutional CDs.

Are you planning on running all those off at this point?

Seems like you have enough liquidity to do that and get rid of the $2.4 billion in wholesale and still have enough for loan growth.

That is correct.

The retail brokered CDs, the 650 that I mentioned in the second quarter is largely the rest of the ones that were put on during the credit crunch.

So those will be gone as of the second quarter, and easily with the excess liquidity we can let those mature as well as the other debt maturities I mentioned.

On the loan spreads comments you made, going through the average balance sheet, it looks like you saw a nice jump in across many of these products.

Can you update us on how far you are through the repricing process, what portion of the portfolio you've repriced and how much in the way of opportunities you have left over?

We will, through this year, be largely finished with the process we began really three years ago.

So that is fully reflected, I think, the full repricing, if you will, by the end of this year.

And so as you guys are looking at an economy which is stabilizing, perhaps slowly improving here, and there are a lot of banks out there including yourselves that have fresh capital and are looking to stabilize and grow loan portfolios, have you at all started seeing any signs of spread compression for some of the stronger credits out there.

Let me take that.

It's clear that with liquidity position, the capital positions of institutions that particularly for the stronger credits, it clearly increased competition.

And it's really across all markets and across all lines of business for the most part.

So we are starting to see more of that.

We've been fortunate that we've been able to hold our structures and our pricing but I think as the economy gets better and people feel better and better and we're beginning to see that right now and as deposits shrink I think you'll start to see loans grow and I think you will see more pressure on the loan spreads.

But for the moment, we've still been able to hold on to the spreads that we put in place.

Okay.

Great.

Thanks, guys.

Appreciate it.

Thank you.

Your next question comes from the line of Ken Usdin, Jr, BOA, Merrill Lynch.

Thanks.

Good morning.

I was wondering if you could give us a little bit more color on the commercial real estate line of business.

You mentioned an expected downward trend of charge-offs with some variability so I'm just wondering what you're seeing underneath both sides of that portfolio, both the construction side and the commercial mortgage side.

Sure.

One important thing to remember, Ken, is that the construction loans are rolling into mini perms.

We're pretty much past the construction risk in that portfolio because we really haven't made very many new construction loans in about three years.

When you talk about the uptick in commercial real estate charge-offs and NPA inflow, I think it's important to put it in proper context, to remember our overall credit trends.

We've seen improvement for three quarters now in charge-offs, NPA inflow and past dues and we've seen improvement for two quarters now in overall NPA provision and the watch list.

The uptick in commercial real estate charge-offs and inflow related to credits that were previously identified and were in fact on the watch list for commercial real estate, they were not a surprise.

They were just moving through the workout process.

And as we analyzed the data, we saw that commercial real estate NPAs were still down in the first quarter.

We saw that the commercial real estate watch list was down by $100 million in the first quarter.

And then we analyzed the commercial real estate migration for the last several quarters and all those items supported our belief that the negative migration is receding.

That being said, there's still a lot of work to do on commercial real estate, as you can see from the absolute numbers and while we think there may be variability as we certainly saw this quarter and as we've said in prior quarters, we think the overall trend is going in the right direction.

And just one follow-up.

Do you -- what's your view on severity in the commercial real estate book as far as future losses as opposed to ones you've taken so far?

Do you believe that you're through the bulk of the worst there as well or do we still have some challenges ahead?

Thanks.

When you think about it by product type, there's no question that the highest loss content is in residential and that's because of the high land content in residential.

We've been working through the residential side of the portfolio, as you know well now for -- feels like forever, but probably more like two and-a-half years.

So we think we're through the largest part of that.

We do think we'll see a few more problems in residential, as well as in retail and multi-family.

But particularly in the nonresidential properties, we expect fewer defaults and lower loss content because of that land factor.

Ken?

I'm all set.

Thank you very much.

Okay.

Thank you.

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

Good morning, Brian.

Good morning, everybody.

Just a quick question, I guess a lot of questions already on capital and the capital deployment.

Ralph, do you think about or are you seeing anything in whether you think about the California markets or Michigan, with FDIC assisted opportunities that you think you may now that you're free of TARP.

What about traditional M&A opportunities, do you think there's anything in the near term that you would be thinking about with all that excess capital or is it just thinking about organic loan growth as the way to deploy that?

Well, I think it's a little bit of all the above.

When we think about FDIC assisted deals, you never know when those are going to come available.

But we have been very regimented as you know on making sure that whether it's an FDIC transaction or whether it's a traditional transaction, that it fits.

It needs to fit in our strategy and accelerate our internal strategy with not only the types of businesses that we're in, but also a culture that fits, because we want to see it accelerate growth and not be a detractor from that standpoint.

And we don't do it just to be a transaction.

Whether they will come up, you never know, and about the time you think nothing's going to come up, it will happen.

Whether it be an assisted or a more traditional transaction, but we are certainly open and looking and understand where we want to be and so we can evaluate those opportunities very quickly.

And John, really quick, can you just give us -- I did listen, I was trying to scribble down but the color on the Texas net charge-offs, was it a permanent commercial real estate or was it commercial real estate development?

There were two projects in particular in Texas, Brian.

As you know, the Texas economy has had a much shallower recession than the rest of the country but they're not immune from the occasional real estate problem.

One of those was a retail development in Dallas.

The other was a rather high end residential development in the Austin area.

And as you well know, it's the high end of residential that hasn't begun to recover very well anywhere in the country, up until this point.

Last quick question for John and maybe Dale.

What I was surprised about is the Midwest market sort of strengthening so quickly as well from a credit perspective and even returning to profitability levels back to even first quarter of last year.

Maybe you guys can kind of talk about what you're seeing there with customers and with the outlook for the Michigan segment.

Well, Brian, let me take at least part of that.

We've spent quite a bit of time up there lately, kind of talking to customers, talking to our people, and there's a renewed sense of optimism, certainly in the middle market and small business.

You have to remember it started from a fairly low level of really not having much optimism.

I think the autos have shown some strengthening, obviously you're seeing GM repaid a substantial part of what they owed the taxpayers.

So I think that's helped.

Without any doubt, we are seeing some good opportunities in that market.

It's not a market that will grow in any kind of a robust fashion, if you believe economic forecasts, probably grows at maybe 1, 1.5% over the next year or so.

I wouldn't suspect we would do much more than that, if that.

I think the good news is the core customer base, we've been through, we've taken whatever lumps we've needed to take and it's really been strong when you consider how long that economy's been in a recession.

I think from a credit quality perspective, things are clearly improving and from a revenue growth perspective I think there are opportunities but I think it's fairly muted.

But nonetheless, we like to see the optimism.

Brian, it's good to see signs of a return to growth in Michigan.

One of the really interesting factors for me is on the auto side.

You know, a tremendous number of suppliers have had a lot of difficulty for the past couple years but those who made it through really restructured the cost side of their business model and as auto sales continue to increase through the late fourth quarter and into the first quarter of this year, at the levels that auto sales are now taking place, these suppliers can make real good profits on that and that's what's driving the Michigan economy in its slight recovery so far.

All right.

Thanks for taking my questions.

Sure.

Thank you.

(Operator Instructions).

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

Good morning, Terry.

Good morning.

Just one question on -- two questions.

First on the change in your guidance on net charge-offs down about $100 million from the fourth quarter and I believe you reiterated that a couple months ago.

If I just annualize the first quarter charge-offs I'm right around the midpoint of that range and was this a tough decision to make?

Obviously there's still some cautiousness out there especially among many of your peers, and could you just talk about beyond just the first quarter trends really what gave you the confidence to come out and make that statement?

Well, your math is certainly correct.

It does hit almost exactly the midpoint of that range and thats was done specifically for that purpose.

We base our forecast on the improvement that we've seen in so many of our basic credit metrics over the past two and in sometimes three quarters, by talking to our customers about what they're seeing in the marketplace, what they're feeling.

So it's all of those things, as well as discussions with our colleagues internally here at the bank.

So it's a number of those things that makes it what we thought was a prudent thing to do to bring the guidance down somewhat and we'll continue to review that as we go forward.

And I think Terry, the point is we made last -- for the fourth quarter as well as the first quarter, there was a broad-based improvement in credit metrics across all of our geographies and across virtually all of our lines of business.

So whether it's provisioning, charge-offs, past dues, inflows, watch list, all of those were headed in the right direction.

And now this is two quarters in a row and remember, our credit quality improvements, frankly, started earlier than many of our peers and we began to foreshadow that last summer and fortunately the trends have picked up and the breadth of the improvements have come to pass and we feel very good about that.

Thanks.

And then just the additional question.

A few years ago when Comerica was more in an offensive mode you were adding banking centers and then have kind of slowed down those efforts.

As you look ahead over the next year or couple years, do you think you'll be growing the number of banking centers like you were in the past few years and is any of that built into your expense guidance for the year?

We will open about 13 this year, and we will, as you just described as the economy begins to strengthen and move forward, we will again ramp up our strategy from an internal standpoint and opening new banking centers, as well as I was mentioning earlier we'll always be looking for the opportunities of acquisitions as well.

Thank you very much.

Thank you.

Your next question comes from the line of Gary Tenner.

Good morning, Gary.

Gary?

Hold one moment, sir.

Okay, that is Gary Tenner of Soleil Securities.

Good morning, Gary.

Good morning.

Can you hear me now?

Yes.

Just a couple questions on the margin.

In terms of the margin guidance.

Does that assume any sort of rising short-term interest rates or is that purely because of the excess liquidity and other organic changes that the margin should expand?

We are not assuming any rate rise from the federal funds rate this year.

Okay.

And if you could also just as a second to that update on the amount of your portfolio that's currently floating rate and what percentage of those have floors?

Yeah, about 80% of our loan portfolio is floating and that's a $41.3 billion portfolio.

Of that, about $3 billion have floors.

So a small amount.

Still only $3 billion.

Okay.

Thank you very much.

Thank you.

Your next question comes from the line of [Joe Stephens of Thrivent Capital].

Good morning, Joe.

Good morning, Ralph.

How are you.

Good morning, Beth.

Good morning, Joe.

Actually all my questions have been answered but nice quarter.

Thank you.

Okay.

Thank you.

And your final question comes from the line of Craig Siegenthaler of Credit Suisse.

Good morning, Craig.

Good morning.

This is actually [Veba] filling in for Craig today.

I was just wondering which particular loan classes or geographies do you expect to drive the loan growth over the remainder of the year?

And also if you could give us some color on the trends that you're seeing in those markets that is giving you confidence that loan demand will return?

Let me the take that.

The growth we're seeing is primarily in the Texas and Western markets.

It's in our core businesses, particularly middle market and small business that we're seeing backlogs growing, but also some of our specialized businesses, particularly technology and life sciences.

The backlogs in those businesses are really growing very nicely across the market segments and, frankly, as I said earlier, the customers we're talking to are feeling a lot more positive.

They're beginning to make investments in fixed assets.

They're beginning to do some hiring, although they're still cautious.

So we're seeing all that begin to happen and we're feeling very good about what we're seeing there.

And I think the other thing we would expect is to see utilizations start to increase.

We are at very low line utilization levels now and we did see from February to March those stabilize.

Whether that's the continuing of -- the beginning of a trend, we'll have to see.

But line utilization and a lot of our loan decline has been through less usage underlying.

So we would expect to see that improve without having to add new customers to get the loan growth.

Great.

Thanks.

Thank you.

I will now turn the call over to Ralph Babb for closing remarks.

I would just like to thank everybody for joining us today and your continued interest in Comerica.

Thank you very much.

This concludes today's Comerica first quarter 2010 earnings conference call.

You may now disconnect.