SecProbe.io

November 6 , 201 2

Via Email
Kevin D. Chapman
Chief Financial Officer
Renasant  Corp.
209 Troy Street
Tupelo, Mississippi   38804 -4827

Re: Renasant Corp .
Form 10-K for the Fiscal Year E nded December 31, 20 11
Filed  March 8 , 2012
Form 10 -Q for the period ended June  30, 2012
Filed  August 9 , 2012
File No. 1-13253

Dear M r. Chapman :

We have reviewed your filing, and have the following comments.   In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
respo nse.  Where we have requested changes in future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosures.   If you do not believe our
comm ents apply to your facts and circumstances or do not believe an amendment is appropriate,
please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additi onal comments.

December 31, 2011 Form 10 -K

Business, page 1

1. With regards to your first risk factor on page 14, and noting your loan portfolio change to
focus on commercial mortgages instead of construction loans, revise here (or pr ovide as
trend information in the MD&A) to describe changes in economic conditions in the
markets in which you operate during the periods presented by the financial statements.
This might include, for example, changes in average income, unemployment, and
commercial  vacancy rates, etc.

Kevin D. Chapman
Renasant  Corp.
November 6 , 2012
Page 2

Note D – Loans and the Allowance for Loan Losses, page 80

2. In your roll forward of restructured loans on page 82, you show loans reclassified to
nonperforming as decreasing the balance of restructured loans.  Please explain  to us what
this line item represents and why the balance of restructured loans decreased due the loan
being classified as nonperforming.  We note that loans that meet the definition of a
troubled debt restructuring can be accruing or non -accruing and that  banks generally
include both accruing and non -accruing restructurings in their troubled debt restructuring
disclosure.

June 30, 2012 Form 10 -Q

Note H – Fair Value Measurements, page 26

3. Please revise future filings to provide quantitative information about the significant
unobservable inputs (e.g. estimated selling costs, etc.) used in the fair value measurement
for each class of your nonrecurring measurements categorized within level 3.  Refer to
ASC 820 -10-50-2-bbb for guidance and ASC 820 -10-55-103 for example disclosure.

Management’s Discussion and Analysis of Financial Condition and Results
of Operations, page 36

4. Due to the significance of net interest margin on your results of operations, please revise
future interim filings to include a rate/v olume analysis similar to the analysis on page 12
of your December 31, 2011 Form 10 -K.  We note Item 303(b) of Regulation S -K.

5. We note significant discussion and analysis of your results of operations for the periods
presented except for the underlying reasons for trends and changes in your credit quality.
Please tell us in detail and revise future filings to provide more qualitative discussion of
the trends in your credit quality and to more comprehensively bridge the gap between the
changes in the cre dit quality of your loan portfolio and the amount of your provision for
loan loss recorded during the period and the amount of the allowance for loan losses at
period end.

Signature Page

6. Pursuant to the signature requirements for Form 10 -K, please revise  to identify
 the person serving in the capacity of principal accounting officer.

Kevin D. Chapman
Renasant  Corp.
November 6 , 2012
Page 3

             We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the informati on the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclos ures they have made.

            In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under th e federal securities laws of the United States.

You may contact Michael Volley at (202) 551 -3474 or John Nolan, Senior Assistant
Chief Accountant, at (202) 551 -3492 if you have any questions regarding comments on the
financial statements and related matt ers.  Please contact David Lyon  at (202) 551 -3421  or me  at
(202) 551 -3434 with any questions.

Sincerely,

 /s/ Michael R. Clampitt

            Michael Clampitt
Senior Attorney