Comerica Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Comerica describes a defined mechanism for aligning its lobbying through trade associations, stating that “Comerica’s Director of Corporate Sustainability reviews our list of trade associations with which we paid a membership fee in the reporting year to determine whether the work of those organizations is consistent with our overall climate strategy,” and noting that “when working directly with banking trade associations on climate-related issues, we work to provide feedback and context to balance the overall needs of our diverse industry with our own climate priorities and initiatives.” This review process is overseen by a named individual—the Director of Corporate Sustainability—and climate matters are escalated to the Board’s Enterprise Risk Committee, which “receives regular updates from Comerica’s Director of Corporate Sustainability.” However, the company does not disclose any process for aligning its direct lobbying activities with its climate goals, no policy for board sign-off on climate advocacy, and acknowledges that it has “No, and we do not plan to have one in the next two years” in response to conducting engagement in line with the Paris Agreement. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Comerica describes a defined mechanism for aligning its lobbying through trade associations, stating that “Comerica’s Director of Corporate Sustainability reviews our list of trade associations with which we paid a membership fee in the reporting year to determine whether the work of those organizations is consistent with our overall climate strategy,” and noting that “when working directly with banking trade associations on climate-related issues, we work to provide feedback and context to balance the overall needs of our diverse industry with our own climate priorities and initiatives.” This review process is overseen by a named individual—the Director of Corporate Sustainability—and climate matters are escalated to the Board’s Enterprise Risk Committee, which “receives regular updates from Comerica’s Director of Corporate Sustainability.” However, the company does not disclose any process for aligning its direct lobbying activities with its climate goals, no policy for board sign-off on climate advocacy, and acknowledges that it has “No, and we do not plan to have one in the next two years” in response to conducting engagement in line with the Paris Agreement.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Comerica provides only limited insight into its climate-related lobbying. It notes that it participates in the Climate Safe Lending Fellowship program and leads the Bank Sustainability Roundtable, indicating some indirect mechanisms of engagement, but it does not identify any specific government bodies, legislators, or regulators it seeks to influence, nor does it describe direct tactics such as letters, testimony, or meetings. The company offers no disclosure of particular climate policies, bills, or regulations it has lobbied on, and it does not set out the concrete policy changes or outcomes it is trying to achieve. As a result, while Comerica acknowledges involvement in broad sustainability initiatives, it does not supply the detail needed to understand what climate policy it is engaging on, how it is doing so, or what it hopes to accomplish.	D