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     Response Letter

June 2, 2005

Mr. Paul Cline

Senior Accountant

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C.  20549

Re:

First Horizon National Corporation Form 10-K

                                          Filed March 14, 2005

                                          File No. 001-15185

Dear Mr. Cline:

First Horizon National Corporation
(the “Company”) is in receipt of the letter from the staff (the
“Staff”) of the Securities and Exchange Commission, dated May 5, 2005, regarding
the above-referenced filing.

To facilitate the Staff’s
review, we have included in this letter the captions and numbered comments from the
Staff’s comment letter in bold, italicized text, and have provided our responses
immediately following each comment.

In some of our responses, we have
agreed to supplement the disclosure in our future filings. We are doing that in the spirit
of cooperation with the Staff, and not because we believe our prior filing is materially
deficient or inaccurate. Accordingly, any changes implemented in our future filings should
not be taken as an admission that our prior disclosures were in any way deficient.

We have also indicated in some of our
responses that we believe no change in disclosure is appropriate, and have explained why.
We understand the Staff’s comments, even where a disclosure change is requested or
suggested, to be based on the Staff’s understanding based on information available to
it, which may be less than the information available to us. Accordingly, we understand
those Staff comments may be withdrawn or modified based on the additional explanation or
information we provide.

In response to your first, third and
fourth comments, we have agreed to revise our disclosures in the notes to our
audited consolidated financial statements, specifically Note 1 — Summary of
Significant Accounting Policies, in our future filings. For your convenience, we have
included a sample of the disclosure that we currently intend to include in future filings as Annex I
to this letter. Please note that the proposed disclosure includes additional information
intended to clarify which of the Company’s hedging relationships are strictly
economic in nature, and which are entered into both for economic and hedge accounting
benefits. In response to your second comment, we have included the requested supplemental
information.

Page 1

1.  Summary of Significant
Accounting Policies – page 60

Please revise your SFAS
No. 133 derivative disclosures as follows:

a.

Clearly
describe the specific methodology used to evaluate both prospective and retrospective
hedge effectiveness for each hedging relationship (for example, the pipeline and the
warehouse, MSR’s, interest-only securities)

b.

Disclose
how often hedge effectiveness tests are performed

We will revise the Mortgage Banking
section of Note 1 — Summary of Significant Accounting Policies in
future filings so that it more fully describes both our prospective and
retrospective evaluations of hedge effectiveness, including the frequency with
which such tests are performed. (See paragraphs 3 and 5 of our proposed
Mortgage Banking disclosure.)

To supplementally answer your comment, in
accordance with SFAS No. 133, as amended by SFAS No. 149, interest rate lock
commitments (IRLC) are considered derivatives and are marked to market. The
interest only securities are classified as trading securities and are fair value
assets. Neither IRLC nor interest only securities are eligible for hedge
accounting pursuant to SFAS No. 133 although both are hedged for economic
purposes, as described in our proposed revised disclosure. (See paragraphs 1 and
8 of our proposed Mortgage Banking disclosure.)

c.

Quantify
and disclose where on the balance sheet and income statement you classify your SFAS
133 qualifying fair value hedges and related hedged items for each major hedging
relationship.

The only SFAS No. 133 qualifying hedges relate to
the warehouse and MSR. The Mortgage Banking section of
Note 1 — Summary of Significant Accounting Policies in our future
filings will include the dollar amounts and balance sheet classification of
assets which are hedged pursuant to SFAS No. 133 and their related hedges. (See
paragraphs 4 and 6 of our proposed Mortgage Banking disclosure.) In addition, we
are clarifying our ineffectiveness disclosures which are already included in
Note 1 to address your request for income statement quantification and location.
The balance sheet classification of MSR was not separately disclosed in Note 1
as this asset is shown separately on the face of the balance sheet.

In addition, we will revise the
Interest Rate Risk Management section of Note 1 — Summary of
Significant Accounting Policies in our future filings to quantify and disclose
the balance sheet location of qualifying SFAS No. 133 fair value hedges and
related hedged items. (See Interest Rate Risk Management section of our
proposed disclosure.)

Page 2

2. Specifically related
to your fair value hedges of MSR, supplementally tell us in detail the following:

a.

The
significant components of servicing income in your table on page 10. Specifically tell us
the gross amount of hedge gains/losses offset by the change in fair value of the hedged
MSR;

The requested supplemental information with
respect to components of servicing income, including hedged MSR gains and
losses, is set forth in the following table for the fiscal years ended December
31, 2004, 2003 and 2002:

     (thousands of dollars)

     2004
     2003
     2002

     SFAS 133 Basis Adjustment to MSR

     (18,340
        )
     115,673

     (358,492
        )

     SFAS 133 Change in Fair Value MSR Hedge due to Effectiveness
     18,340

     (115,673
        )
     358,492

     Net Interest Income on Swaps
     79,949

     111,948

     108,732

     Hedge Time Decay
     (33,403
        )
     (16,528
        )
     (21,239
        )

     Other Hedge Ineffectiveness
     1,373

     19,715

     13,255

     Net G/L MSR Hedges
     47,919

     115,135

     100,748

     Gross Service Fees
     294,315

     248,375

     198,828

     Early Payoff Interest Expense
     (21,162
        )
     (34,473
        )
     (20,225
        )

     Guarantee Fees
     (64,755
        )
     (48,579
        )
     (31,440
        )

     Amortization
     (152,722
        )
     (132,274
        )
     (117,842
        )

     Impairment
     (37,062
        )
     (158,324
        )
     (150,162
        )

     Ancillary and Other Income
     17,263

     18,326

     9,861

     Total Servicing Income
     83,796

     8,186

     (10,232
        )

b.

How
you apply paragraph 21 of SFAS 133;

Per paragraph 21 (subparagraphs b.
and c.), MSR are hedgable assets because their value is at risk for changes in interest
rates. Consistent with the provisions of paragraphs 20 and 21 (subparagraphs a., b. and
f.), the Company hedges the change in the fair value of the MSR asset attributable solely
to the change in the benchmark interest rate. The 10-Year LIBOR Swap rate has been
selected as the benchmark interest rate, which complies with paragraph 21 (subparagraph
f.) and the definition of “benchmark interest rate” as presented in paragraph
540 (as amended by SFAS No. 138). Paragraph 21 (subparagraph a.1.) requires that a hedged
portfolio of similar assets must share the risk exposure for which they are hedged. The
Company performs a similar asset test on a monthly basis, or more frequently if necessary,
to aggregate the MSR assets of its loan servicing portfolio into SFAS No. 133 hedge
strata. The similar asset test is performed by measuring price sensitivity over the
following rate shock scenarios: up and down 25 bps and 50 bps, respectively.

c.

How
you measure both prospective and retrospective hedge effectiveness of this hedging
relationship. For instance, how do you calculate the change in the fair value of your MSR
related to changes in the benchmark interest rate;

The Company performs prospective
analyses of hedge effectiveness as required by paragraph 20 (subparagraph a.) and
consistent with the discussions documented in DIG Issue E7. Prior to acquiring a new hedge
instrument, an historical

Page 3

 regression analysis is performed between the
underlying index of the proposed hedging instrument and the underlying index of
the hedged item. The analysis is performed over 6-month, 1-year and 2-year time
horizons. High correlation exists when the regression coefficients
(r2) for each time horizon are above 80%.

Pursuant to paragraph 20
(subparagraph b.), at the end of each hedge period the Company computes the change in the
fair value of the MSR asset due solely to the change in the benchmark interest rate and
the change in the fair value of the derivative for each specific risk tranche. The result
of this calculation becomes an historical data point. As permitted in DIG Issue E7, the
Company performs a regression analysis of all collected data points over a rolling
12-month period to determine retrospective effectiveness. The Company believes that
retrospective hedge effectiveness has been established if the regression results meet all
of the following criteria:

For all hedge periods up to
12/31/2004

•

Coefficient
of correlation (r) > 0.80

•

Slope
of regression line between 0.80 and 1.25

For all hedge periods after
12/31/2004

•

Regression
Coefficient (r2) >0.80

•

Slope
of regression line between 0.80 and 1.25

•

Pass
F-Test

The new (post-2004) effectiveness
criteria would have had no material impact if applied in 2004, 2003 and 2002. The
enhancement was made to conform to evolving industry-best practices.

In order to determine the change in
the fair value of the MSR asset due to the change in the benchmark interest rate for any
given hedge period, the Company compares the value of the MSR portfolio at the beginning
of the hedge period with the value at the end of the hedge period using a “Same Tape,
Different Assumptions” approach. This approach uses the same loan portfolio
(servicing tape) for both valuations. The interest rates used in the valuation model are
changed in accordance with the change in the benchmark interest rate. While the interest
rates used at the beginning of the period represent actual market rates, the interest
rates used at the end of the period represent a parallel shift equal to the change in the
benchmark interest rate from the beginning of the period to the end of the period. The
interest rate driven assumptions in the MSR valuation model include: mortgage rate,
earnings rate, cost of funds rate, and all underlying indices for ARM loans. By parallel
shifting only interest rates, the Company can isolate the change in the fair value of the
MSR due to the change in the benchmark interest rate, a methodology which complies with
the provisions of paragraph 20 (subparagraph b.). This methodology also complies with
paragraph 24 of SFAS No. 138 because no contractual cash
flows of the MSR are excluded in determining the change in fair value attributable to
movements in the benchmark interest rate.

Page 4

d.

We
note on Page 41, that you do not specifically hedge the change in fair value of MSR
attributed to unanticipated prepayments (representing the difference between actual
prepayment experience and estimated prepayments derived from a model).

(i)  How you calculate the change in fair value related to unanticipated prepayments.

The Company only hedges the change in
fair value attributable to the change in the benchmark interest rate, as permitted by
paragraph 21 of SFAS No. 133. Since we use the “Same Tape, Different
Assumptions” approach to isolate the change in MSR fair value attributable to the
change in the benchmark interest rate, we do not perform a specific calculation to
determine the change in fair value due to unanticipated prepayments. However, the impact
of all unhedged risks (which includes but is not limited to unanticipated prepayments) is
captured by the SFAS No. 140 impairment test. Any changes in the fair value of the MSR
asset, whether they are hedged, anticipated or otherwise quantified, are captured when
calculating the fair value of the MSR asset as part of the SFAS No. 140 impairment
test. Historically, unanticipated prepayments have been the primary driver of impairment
expense.

(ii)  How you include the effect of unanticipated prepayments on the fair value of MSR in
your prospective and retrospective effectiveness calculations.

Since unanticipated prepayments are
not part of the Company’s designated risk, the effect of unanticipated prepayments on
the fair value of the MSR is not included in the prospective and retrospective
effectiveness calculations.

3. Please revise to
disclose how you apply paragraph 27 of SFAS 133 to your MSR impairment tests.

We will revise the Mortgage Banking section of
Note 1 — Summary of Significant Accounting Policies in our future
filings in order to discuss our tests for impairment and how impairment impacts
earnings. (See paragraph 7 of the proposed Mortgage Banking disclosure.)

4. Please revise to
disclose if you use different stratification criteria for your MSR impairment tests and
for the purposes of grouping similar assets to be designated as a hedged portfolio in
your fair value hedges. If you do, tell us how you consider the fair value hedge
market value adjustments in your impairment tests.

We will revise the Mortgage Banking
section of Note 1 — Summary of Significant Accounting Policies in our
future filings in order to disclose that the stratification criteria differ, and
to explain that fair value hedge market adjustments are allocated to the loan
level which allows for re-stratification for the impairment test. (See paragraph
7 of the proposed Mortgage Banking disclosure.)

Page 5

First Horizon National Corporation
acknowledges that it is responsible for the adequacy and accuracy of the disclosure in its
Form 10-K, that Staff comments or changes to disclosure in response to Staff comments do
not foreclose the Commission from taking any action with respect to the filing, and that
the Company may not assert Staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

We hope these responses adequately
address the questions raised in your letter. Any questions with respect to the foregoing
should be directed to the undersigned at (901) 523-5620.

Sincerely,

/s/ Marlin L. Mosby III

Marlin L. Mosby III

Executive Vice President and Chief Financial Officer

Page 6

First Horizon
National Corporation Form 10-K

Annex I

Excerpts from Proposed Note 1 Disclosure

(The following are the applicable
excerpts from Note 1 — Summary of Significant Accounting Policies as we currently
expect them to appear in our future filings)

Derivative financial
instruments.

Mortgage Banking

Mortgage banking interest rate lock
commitments (IRLC) are short-term commitments to fund mortgage loan applications
in process (the pipeline) for a fixed term at a fixed price. During the term of
an IRLC, First Horizon Home Loans has the risk that interest rates will change
from the rate quoted to the borrower. First Horizon Home Loans enters into
forward sales contracts with respect to fixed rate loan commitments and futures
contracts with respect to adjustable rate loan commitments as economic hedges
designed to protect the value of the IRLC from changes in value due to changes
in interest rates. Under SFAS No. 133 IRLCs qualify as derivative financial
instruments and as such do not qualify for hedge accounting treatment. As a
result, the IRLCs are recorded at fair value with changes in fair value recorded
in current earnings as gain or loss on the sale of loans in mortgage banking
noninterest income. See Accounting Changes section for impact of SAB No. 105 on
t