Christine Moore
COMERICAAbout Christine Moore
Christine M. Moore is Executive Vice President and Chief Audit Executive at Comerica (since January 2025), age 62, and has been an executive officer since 2016. She leads Comerica’s internal audit function, reporting to the Audit Committee, and is responsible for evaluating and opining on the effectiveness of Comerica’s internal controls, policies, and procedures . Company performance context over the last five years shows MIP EPS of $5.14 (2020), $6.12 (2021), $6.83 (2022), $8.10 (2023), and $5.63 (2024), Net Income of $497M (2020), $1,168M (2021), $1,151M (2022), $881M (2023), and $698M (2024), and cumulative 5-year TSR of 11% vs 33% for the KBW Bank Index .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Comerica Incorporated / Comerica Bank | Chief Audit Executive (EVP) | Jan 2025 – Present | Heads internal audit; evaluates effectiveness of internal controls, policies, and procedures; reports to Audit Committee |
| Comerica Incorporated / Comerica Bank | General Auditor (EVP) | May 2016 – Jan 2025 | Led internal audit function; audit oversight and control evaluation |
| Comerica Incorporated / Comerica Bank | Senior Vice President; Deputy General Auditor | Sep 2013 – May 2016 | Deputy leadership for audit; strengthened audit governance |
| Comerica Incorporated / Comerica Bank | Senior Vice President; Audit Director | Jan 2007 – Sep 2013 | Directed audit programs; enhanced risk and compliance controls |
Fixed Compensation
- AEI program participation: NEOs and other senior leaders (~395) participate in the Annual Executive Incentive (MIP) using MIP EPS, MIP Efficiency Ratio, and strategic initiatives . As an EVP, Moore is within senior leadership scope.
- AEI target percentages by level:
- CEO: 150%; CFO: 100%; Other NEOs: 90% .
- EVP (promotion cohort reference): EVPs targeted at 90% of base (January 2023 committee action for Crespi, Sefzik, Oberg) .
Performance Compensation
2024 AEI Metrics and Outcomes
| Metric | Weight | Target | Actual | Corporate Funding Basis |
|---|---|---|---|---|
| MIP EPS | 65% | $5.18 | $5.63 | 136% metric funding → 88% weighted |
| MIP Efficiency Ratio | 15% | 68% | 69% | 97% metric funding → 14% weighted |
| Strategic Initiatives – Risk Mgmt | 10% | 100% | 97% | 9% weighted |
| Strategic Initiatives – Growth | 5% | 100% | 100% | 5% weighted |
| Strategic Initiatives – Human Capital | 5% | 100% | 106% | 6% weighted |
| Total Corporate Funding | — | — | — | 122% baseline funding |
- Program design: One-year measurement; funding increases/decreases per formula; strategic initiatives reinforce risk discipline, growth, and human capital .
Equity Programs (LTI)
| Instrument | Metrics | Vesting | Key Terms |
|---|---|---|---|
| SELTPP (Performance Units) | Absolute 3-year SELTPP ROCE; Relative ROCE vs KBW Bank Index; 15% TSR modifier | 3-year performance period (e.g., 2024–2026), payout capped at 150% | Absolute ROCE target 9–11%; no funding <4%; payouts can be reduced with bottom-quartile TSR; dividends accrue and pay only if units vest |
| RSUs (Time-based) | n/a | 50% in year two, 25% in year three, 25% in year four | Dividends accrue and are paid only if RSUs vest |
| Stock Options (discontinued in 2025 grants) | n/a | 25% per year over four years; 10-year term | Exercise price at grant close; program discontinued beginning Jan 2025 grants; LTI mix now 60% SELTPP / 40% RSUs |
Equity Ownership & Alignment
- Stock ownership guidelines (updated for 2025): Salary multiples by internal grade; retention requirement added—officers must retain 50% of after-tax shares from each vesting/exercise until guideline met . | Level | Salary Multiple | |---|---:| | CEO | 6x | | CFO | 3x | | Sr. EVP/EVP (Level II) | 3x | | EVP (Level I) | 2x |
- Hedging and pledging prohibited; employees/officers/directors may not hedge, hold in margin accounts, or pledge Comerica securities .
- None of management’s reported shares are pledged; Comerica does not permit hedging/pledging .
Employment Terms
- Reporting line: Chief Audit Executive reports to the Audit Committee; responsible for internal controls, compliance with legal/regulatory requirements through audit oversight .
- Change-of-control agreements: Maintained for NEOs with 30-month employment period and severance of 3x salary+highest annual bonus, benefit continuation, equity acceleration terms (pre-2018 single trigger; post-2018 double trigger if not assumed), and outplacement; current agreements after 2008 exclude excise tax benefit/window period; payments reduced to avoid excise tax where beneficial .
- Compensation governance: Two clawback policies (Dodd-Frank compliant Compensation Recovery Policy and discretionary Recoupment Policy); equity plan forfeiture/cancellation rights for misconduct/risk failures; SOX clawback for CEO/CFO . SELTPP agreements also include forfeiture/cancellation and change-in-control settlement mechanics .
Company Performance Context (for pay-for-performance analysis)
| Metric | FY 2020 | FY 2021 | FY 2022 | FY 2023 | FY 2024 |
|---|---|---|---|---|---|
| MIP EPS ($) | 5.14 | 6.12 | 6.83 | 8.10 | 5.63 |
| Net Income ($USD Millions) | 497 | 1,168 | 1,151 | 881 | 698 |
| TSR – Value of $100 Investment ($) | 83 | 134 | 107 | 95 | 111 |
Additional governance signals:
- 2024 Say-on-Pay approval: For 93,674,850; Against 5,690,387; Abstain 399,052; Broker non-votes 14,825,417 .
- 2025 compensation design change: Stock options discontinued; LTI mix shifted to 60% SELTPP / 40% RSUs; peer group unchanged after review .
Investment Implications
- Compensation alignment: Strong performance linkage through AEI (weighted to MIP EPS) and SELTPP (absolute/relative ROCE with TSR modifier), with explicit clawbacks and forfeiture provisions—supports risk-aware incentives aligned with shareholder outcomes .
- Retention and selling pressure: 2025 update requires retaining 50% of after-tax shares until stock ownership multiples are met, and hedging/pledging is prohibited—reduces near-term selling pressure and increases alignment .
- Governance risk mitigants: CAE role reporting to Audit Committee strengthens controls; change-of-control economics are limited to NEOs; no company use of repricing; excise tax gross-up excluded from post-2008 agreements .
- Program evolution: Discontinuation of options in 2025 lowers optionality risk, emphasizes full-value equity (RSUs, PSUs), and aligns with regulatory expectations—beneficial for retention and reduces volatility in realized comp .
Notes: Christine Moore is not listed as an NEO; her specific salary, bonus, grant values, and personal equity holdings are not disclosed in the proxy. Program and policy data above apply to senior executives and NEOs as cited.