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First Horizon National Corporation

February 10,
2020

VIA EDGAR AND FEDEX

Division of Corporation Finance

Office of Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Sonia Bednarowski

    Re:
    First Horizon National Corporation

    Registration Statement on Form S-4

    Filed December 31, 2019

    File No. 333-235757

Dear Ms. Bednarowski:

On behalf of First
Horizon National Corporation (“First Horizon”), and in response to the comments of the staff (the “Staff”)
of the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “Commission”)
to First Horizon’s registration statement on Form S-4 filed with the Commission on December 31, 2019 (the “Registration
Statement”) contained in your letter dated January 24, 2020 (the “Comment Letter”), I submit this letter containing
First Horizon’s responses to the Comment Letter. The responses set forth in this letter are numbered to correspond to the
numbered comments in the Comment Letter. For your convenience, we have set out the text of the comments from the Comment Letter
in bold text followed by our response.

In connection with
this letter, we are filing an amendment to the Registration Statement (“Amendment No. 1”) on the date hereof. Page
numbers referenced in the responses refer to page numbers in Amendment No. 1.

Cover Page

 1. Please disclose here
                                         the number of depositary shares representing 1/400th of an interest of First Horizon
                                         Series B preferred stock, First Horizon Series C preferred stock and First Horizon Series
                                         D preferred stock and the underlying Series B, Series C and Series D shares of preferred
                                         stock that you are offering. In addition, please disclose the aggregate value of the
                                         merger consideration.

Securities and Exchange Commission

February 10, 2020

Page 2

RESPONSE:

In response to the
Staff’s comment, First Horizon has (1) revised the cover page of the registration statement to disclose the number of depositary
shares being registered and (2) separately disclosed the aggregate value of the merger consideration on the cover page of the
joint proxy statement/prospectus.

Summary

Interests of Certain First Horizon
Directors and Executive Officers in the Merger, page 22

 2. We note that, in connection
                                         with the merger, named executive officers of First Horizon and IBKC will receive grants
                                         of closing incentive restricted stock awards. Please revise to include quantitative information
                                         regarding these awards here. In addition, please provide a brief summary of the terms
                                         of Mr. Byrd’s compensation following the closing of the merger, including quantitative
                                         information.

RESPONSE:

In response to the
Staff’s comment, First Horizon has revised the disclosure on pages 22, 23 and 24 of Amendment No. 1.

Governance of the Combined Company
After the Merger

Bylaws, page 24

 3. Please provide a brief
                                         summary of the amendments to the bylaws of First Horizon here and discuss such amendments
                                         in greater detail in an appropriate section of your prospectus. In this regard, we note
                                         your disclosure that the merger agreement requires First Horizon to implement “certain
                                         governance matters for the combined company following the completion of the merger.”

RESPONSE:

In response to the
Staff’s comment, First Horizon has revised the disclosure on pages 24 and 132 of Amendment No. 1 to briefly summarize
the amendments to the bylaws of First Horizon that will be adopted in connection with the closing of the merger and to clarify
that the related subsections of “Summary—Governance of the Combined Company After the Merger” and “The
Merger—Governance of the Combined Company After the Merger” describe in more detail the substance of the foregoing
bylaw amendments.

Combining First Horizon and IBKC may
be more difficult, page 44

 4. Please disclose the
                                         “anticipated cost savings” from combining the businesses of First Horizon
                                         and IBKC in an appropriate section of your prospectus and disclose a brief description
                                         of how you calculated such cost savings, to the extent practicable, or advise. In addition,
                                         we note your disclosure regarding the transaction and

Securities and Exchange Commission

February 10, 2020

Page 3

integration costs in connection
with the merger on page 48. Please provide an estimate of the expected transaction and integration costs here, or advise.

RESPONSE:

In response to the
Staff’s comment, First Horizon has revised the disclosure on pages 45 and 49 of Amendment No. 1.

Risk Factors

In connection with the merger, First
Horizon will assume IBKC’s outstanding debt obligations and preferred stock, page 48

 5. Please disclose here
                                         quantitative information regarding IBKC’s outstanding debt obligations, so that
                                         investors can assess the risk.

RESPONSE:

In response to the Staff’s comment, First Horizon
has revised the disclosure on page 50 of Amendment No. 1.

The Merger

Background of the Merger, page 67

 6. We note your disclosure
                                         that each of the board of directors of IBKC and First Horizon reviewed and assessed their
                                         respective strategic opportunities from time-to-time. Your disclosure does not appear
                                         to mention any discussions of business combinations by First Horizon with any entities
                                         other than IBKC. Please explain the extent to which First Horizon considered opportunities
                                         with any other companies during this time period. If no other companies were considered
                                         as potential merger partners, please explain why First Horizon did not expand its search.

RESPONSE:

In
response to the Staff’s comment, First Horizon has revised the disclosure on page 70 of Amendment No. 1.

 7. We note the disclosure
                                         that the financial advisors reviewed projections provided by First Horizon and IBKC.
                                         Please disclose any material projections that were provided by First Horizon to IBKC
                                         or its financial advisers as well as any material projections that were provided by IBKC
                                         to First Horizon or its financial adviser. Alternatively, please tell us why you believe
                                         that such disclosure is not material to an investor’s voting decision. We also
                                         note that Morgan Stanley reviewed certain financial projections furnished to it by the
                                         management of IBKC and First Horizon. In this regard, we note that you have included
                                         the unaudited financial forecasts that were provided by IBKC and First Horizon to KBW
                                         and Goldman Sachs for the purpose of performing financial analyses in connection with
                                         their respective opinions.

Securities and Exchange Commission

February 10, 2020

Page 4

RESPONSE

In response to the Staff’s comment, First Horizon
has revised the disclosure on pages 111 through 116 of Amendment No. 1.

 8. We note your disclosure
                                         on page 71 that, at a meeting held by the IBKC board with members of IBKC’s management
                                         on October 15, 2019, IBKC reviewed the process conducted to date with respect to looking
                                         at “both potential buyers of IBKC.” Please disclose the material facts related
                                         to these potential buyers of IBKC. In this regard, we note that the IBKC was in discussion
                                         with Party A but that these discussions ended on August 30, 2019, when Party A communicated
                                         that it was no longer interested in a merger with IBKC. In addition, we note your disclosure
                                         that, on October 20, 2019, Sullivan & Cromwell provided a term sheet to Simpson
                                         Thacher that outlined the proposed terms of Mr. Byrd’s employment with First Horizon
                                         following the closing of a transaction and that, on October 31, 2019, First Horizon provided
                                         IBKC with a draft of Mr. Jordan’s employment agreement to be effective upon and
                                         subject to the closing of the merger. Please provide a summary of the material terms
                                         of these agreements and any material negotiations or discussions regarding these agreements.
                                         Similarly, please describe in greater detail the discussions and negotiations regarding
                                         the exchange ratio, including which party initially proposed the consideration, and whether
                                         either party proposed changes to it as negotiations continued.

RESPONSE

Rather than
referring to specific potential buyers of IBKC, the reference on page 71 regarding “both potential buyers of
IBKC” was intended to refer to possible alternative types of strategic transactions that could be undertaken by IBKC,
specifically to either enter into a transaction (1) pursuant to which IBKC was acquired or (2) pursuant to which IBKC either
acquired another entity or engaged in a merger of equals. In response to the Staff’s comment about potential buyers of
IBKC, First Horizon has revised the disclosure on page  73 of Amendment No. 1 to eliminate any cause of confusion.

In response to the Staff’s comment about the employment agreements,
Fist Horizon has revised the disclosure on pages  73, 74 and 75 of Amendment No. 1.

In response to the
Staff’s comment about the discussions and negotiations regarding the exchange ratio, First Horizon has revised the
disclosure on pages 70 and 71 of Amendment No. 1.

Opinions of IBKC’s Financial
Advisors

Opinion of Keefe, Bruyette &
Woods, Inc., page 88

 9. We note the disclosure
                                         on page 91 that, because the estimates used in KBW’s analyses are inherently subject
                                         to uncertainty, KBW assumes no responsibility or liability for their accuracy. Please
                                         remove this disclaimer and all similar disclaimers, including Goldman Sachs’ disclaimer
                                         on page 107 that none of IBKC, Goldman Sachs or any other person assumes responsibility
                                         if future results are materially different from those forecast,” because, while
                                         it is acceptable for a financial advisor to include language that qualifies the estimates
                                         or analyses or describes the uncertainties, it cannot disclaim responsibility for them.
                                         In addition please disclose the compensation IBKC paid to KBW or its affiliates during
                                         the past two years. In this regard, we note your disclosure on page 98 that in the past
                                         two years KBW provided investment banking or financial advisory services to IBKC and
                                         received compensation for such services. Similarly, disclose any material relationship
                                         that existed during the past two years between Goldman Sachs and its affiliates and IBKC,
                                         if any.

Securities and Exchange Commission

February 10, 2020

Page 5

RESPONSE:

In response to the Staff’s comment
about disclosure of relationships with, and services provided to, IBKC, First Horizon has revised the disclosure on pages 100
and 111 of Amendment No. 1. With respect to the portion of the Staff’s comment to remove language referenced by the
Staff on pages 91 and 107 of the S-4, First Horizon supplementally advises the Staff that both KBW and Goldman Sachs
respectfully disagree with the Staff’s conclusion, and the response in the ensuing paragraphs represents the position
taken by KBW and Goldman Sachs that First Horizon hereby presents to the Staff on their behalf.

KBW and Goldman Sachs believe that the relevant
language in their respective disclosures is appropriate because, as a factual matter, the underlying estimates used in their respective
analyses were provided to them by IBKC and/or First Horizon. Such information is the responsibility of IBKC and/or First Horizon,
and neither IBKC nor First Horizon are disclaiming responsibility for the information that each provided to the financial advisors.

Unlike in past circumstances in which the
Staff has requested that similar language regarding projections be removed, the language in KBW’s and Goldman
Sachs’ disclosures disclaiming responsibility applies to the applicable financial advisor rather than the issuer or the
party to the transaction which prepared the estimates used in such financial advisor’s analyses. In this case, such
estimates were provided to KBW and Goldman Sachs by IBKC and/or First Horizon. Neither KBW nor Goldman Sachs independently
verified such estimates and, accordingly, neither assumed responsibility or liability for their accuracy. When rendering a
fairness opinion, it is customary for financial advisors to disclaim responsibility for independent verification of the
accuracy of the financial statements, data and other information that are furnished by the client because, among other
things, such information was provided to the financial advisor. Such disclaimers of responsibility are consistent with the
terms of the engagement letters that IBKC has entered into with KBW and Goldman Sachs.

Neither KBW nor Goldman Sachs believes that the referenced language in the S-4
disclaims responsibility for their respective analyses. Rather, KBW and Goldman Sachs view their respective disclosure in the
S-4 as appropriately informing IBKC’s shareholders about an important qualification regarding the scope of their
respective opinions as well as the analyses they performed. For the foregoing reasons, no modifications have been made to the
registration statement in this regard except, on page 110 of Amendment No. 1, to remove references to “IBKC” or
“any other person” to make clear that such qualification only relates to Goldman Sachs.

Opinion of Goldman Sachs &
Co. LLC

Summary of Financial Analyses

Selected Companies Analyses for
IBKC, page 101

 10. We note the disclosure
                                         on page 101 that Goldman Sachs selected publicly traded banking industry companies with
                                         operations that, for purposes of analysis, may be considered “similar to certain