SEC Comment Letter 0000000000-24-014033 to FIRST HORIZON CORP (FHN, FHN-PB, FHN-PC, FHN-PE, FHN-PF) (CIK 0000036966) (FHN)
FIRST HORIZON CORP (FHN, FHN-PB, FHN-PC, FHN-PE, FHN-PF) (CIK 0000036966)
Date: Dec. 19, 2024 · CIK: 0000036966 · Accession: 0000000000-24-014033
AI Filing Summary & Sentiment
File numbers found in text: 001-15185
Letter
December 19, 2024 Hope Dmuchowski Chief Financial Officer First Horizon Corporation 165 Madison Avenue Memphis, TN 38103 Re:First Horizon Corporation Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-15185 Dear Hope Dmuchowski: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Information, page 98 1.We note that your presentation of adjusted tangible common equity represents an individually tailored accounting measure given that the adjustment to exclude unrealized gains (losses) on AFS securities, net of tax has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of this measure from future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Jee Yeon Ahn at 202-551-3673 or Michael Henderson at 202-551-3364
December 19, 2024 Page 2 with any questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
December 19, 2024
Hope Dmuchowski
Chief Financial Officer
First Horizon Corporation
165 Madison Avenue
Memphis, TN 38103
Re:First Horizon Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-15185
Dear Hope Dmuchowski:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Information, page 98
1.We note that your presentation of adjusted tangible common equity represents an
individually tailored accounting measure given that the adjustment to exclude
unrealized gains (losses) on AFS securities, net of tax has the effect of changing the
recognition and measurement principles required to be applied in accordance with
GAAP. Therefore, please remove the presentation of this measure from future filings.
Refer to Question 100.04 of the Division of Corporation Finance’s Compliance
& Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of
Regulation G.
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
Please contact Jee Yeon Ahn at 202-551-3673 or Michael Henderson at 202-551-3364
December 19, 2024
Page 2
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance