Allysun Fleming
COMERICAAbout Allysun Fleming
Allysun C. Fleming, age 44, is Executive Vice President, Payments at Comerica Incorporated and Comerica Bank; she has been an executive officer since 2023, serving as EVP since 2022 and Executive Director of Payments since July 2023 . Prior roles include leadership positions at Wells Fargo focused on customer transformation and treasury management delivery . Company context relevant to incentive alignment: Comerica reported FY2024 EPS of $5.02, return on average common equity of 11.23%, return on average assets of 0.87%, and net charge-offs of 0.10% of average loans, framing pay-for-performance outcomes and long-term equity programs .
| Company Performance Metric | FY 2024 |
|---|---|
| EPS ($) | $5.02 |
| ROE (%) | 11.23% |
| ROA (%) | 0.87% |
| Net charge-offs (% of avg loans) | 0.10% |
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Wells Fargo Bank North America | Head of Customer Transformation | Sep 2021 – Jul 2022 | Led customer-centric transformation initiatives |
| Wells Fargo Bank North America | Head of TM Client Delivery | Apr 2020 – Sep 2021 | Strengthened treasury management delivery capabilities |
| Wells Fargo Bank North America | Leadership Assignment / Head of Make It Easy Program | May 2018 – Apr 2020 | Simplified processes to improve customer experience |
External Roles
No public company directorships or external board roles disclosed for Fleming in the latest proxy. Searched DEF 14A and related filings; none returned for Fleming beyond executive officer biography .
Fixed Compensation
Comerica’s executive compensation design emphasizes market-competitive base salaries as the foundation for variable pay, with adjustments driven by performance, scope, and market benchmarking; increases are not automatic . Specific base salary and target bonus percentages for Fleming are not disclosed; the AEI program applies to NEOs and other senior leaders (approximately 395 individuals) and sets individual cash incentive opportunities as a percentage of base salary, determined by role level .
Performance Compensation
Comerica uses a short-term Annual Executive Incentive (AEI) plan and a long-term Senior Executive Long-Term Performance Plan (SELTPP), complemented by time-based RSUs. AEI metrics and weighting include MIP EPS (65%), MIP Efficiency Ratio (15%), and Strategic Initiatives (20%), measured over one year with formulaic funding bands and negative/positive slopes around targets . The SELTPP is a 3-year performance share program with absolute ROCE targets, relative ROCE vs KBW Bank Index, and a relative TSR modifier (+/–15%), capped at 150% payout .
| AEI Metric (2024) | Target | CMA Actual | Funding Basis | Weighted Funding |
|---|---|---|---|---|
| MIP EPS ($) | $5.18 | $5.63 | 136% metric funding; calc 100% + (9 × 4%) | 88% (136% × 65%) |
| MIP Efficiency Ratio (%) | 68% | 69% | 97% metric funding; calc 100% + (–1 × 3%) | 14% (97% × 15%) |
| Strategic Initiatives: Risk Mgmt | 100% | 97% | 91% metric achievement; funding reflected in weighted calc | 9% (91% × 10%) |
| Strategic Initiatives: Growth | 100% | 100% | 100% metric achievement; target performance | 5% (100% × 5%) |
| Strategic Initiatives: Human Capital | 100% | 106% | 124% metric achievement; above target | 6% (124% × 5%) |
| Total Corporate Funding | — | — | — | 122.4% |
| Long-Term Incentive Design (2024 grants) | Key Terms |
|---|---|
| SELTPP (Performance Units) | 3-year measurement (2024–2026); absolute ROCE 9–11% target range; threshold 4%, max 16%; relative ROCE vs KBW Bank Index; TSR modifier ±15%; payout cap 150% |
| RSUs (time-based) | Vest 50% at year 2, 25% at year 3, 25% at year 4; dividends accrue and pay only if vested |
| Stock Options (2024 program) | Non-qualified; 4-year vest (25% annually), 10-year term; exercise price at grant close |
| 2022–2024 SELTPP payout | Paid at 135% after top-quartile ROCE and bottom-quartile TSR modifier; reflects robust performance calibration |
Note: Comerica discontinued stock options in 2025 annual grants; long-term mix now 60% SELTPP and 40% RSUs to align with market and regulatory expectations .
Equity Ownership & Alignment
Comerica prohibits hedging and pledging of company stock by employees and directors; stock ownership guidelines require multiples of salary with a new retention rule effective 2025 requiring executives to retain 50% of after-tax shares from each settlement/vesting until guideline met . Fleming’s initial SEC Form 3 shows direct common share ownership and a stock option grant.
| Ownership Detail | As of Date | Amount | Terms |
|---|---|---|---|
| Common Stock (Direct) | Jul 25, 2023 | 7,729 shares; includes employee stock plan shares, dividend reinvestment, and RSUs | Direct ownership |
| Employee Stock Options | Vest start Jan 24, 2024; expire Jan 24, 2033 | 2,195 underlying shares at $71.16 strike | Vest in four equal installments; 10-year term |
| Policy Alignment | Details |
|---|---|
| Hedging/Pledging | Prohibited for employees and directors |
| Ownership Guidelines | CEO 6x salary; CFO 3x; Sr. EVP/EVP (Level II) 3x; EVP (Level I) 2x; new 50% after-tax retention until compliance (from 2025) |
Insider filings review: We found Fleming’s Form 3 (initial beneficial ownership). Our search did not return Form 4 transaction filings for Fleming in company document search and insider filings indexes, limiting visibility into any subsequent selling activity; we searched Form 4 and 8-Ks without results pertaining to Fleming .
Employment Terms
| Attribute | Details |
|---|---|
| Current Title | EVP, Payments; Executive Director of Payments since Jul 2023 |
| EVP Tenure | EVP since Jul 2022 (Comerica Bank) / Sep 2022 (Comerica Inc.) |
| Executive Officer Since | 2023 |
| Change-in-Control treatment (equity awards) | Standard SELTPP agreement provides that on a CIC, performance is deemed ≥100% or as certified; if replaced, vesting continues with defined settlement mechanics; if not, awards fully vest per plan and settle per Section 409A conventions; special vesting provisions for termination without cause, good reason, disability, retirement, or death within specified windows . |
| Clawbacks/Forfeiture | Dodd-Frank compliant Compensation Recovery Policy; discretionary Recoupment Policy; equity plan allows cancellation for harmful conduct; forfeiture provisions tied to risk outcomes and policy violations . |
Additional Context: Payments Execution and Value Creation
- CEO commentary highlighted payments as a strategic investment and credited Fleming’s leadership with transformational work in treasury management, payments capabilities, and deposit gathering, aligning with noninterest income growth priorities .
- Fleming was scheduled to present along with the CFO and Chief Banking Officer at the 2025 Morgan Stanley US Financials Conference, underscoring her role visibility and strategic ownership of the payments initiative .
Investment Implications
- Alignment: The mix of variable pay (AEI + SELTPP) and tightened 2025 ownership rules (mandatory 50% after-tax retention until guideline met) strengthen pay-for-performance and reduce misalignment risk; hedging/pledging is prohibited .
- Vesting cadence: Options vest annually starting 2024 and RSUs vest over years 2–4, potentially creating periodic settlement events; monitor insider filings for any sales once Form 4s are filed to assess selling pressure and retention risk .
- Performance linkage: AEI funded at 122.4% in 2024 on above-target MIP EPS and strategic initiatives; SELTPP incorporates absolute ROCE and relative ROCE with TSR modifier, reducing risk of windfalls and anchoring payouts to multi-year value creation .
- Option policy shift: Elimination of stock options in 2025 LTI mix reduces leveraged equity exposure and aligns with bank sector governance trends; expect higher emphasis on ROCE-based PSUs and time-based RSUs .
- Strategic impact: Payments leadership is a core lever for deposit growth and fee income diversification; CEO credited Fleming with transformation in payments and treasury management capabilities, a favorable signal for future noninterest income trajectory .