SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

       May 26, 2011

Mr. C. Randall Sims Chief Executive Officer Home Bancshares, Inc.
719 Harkrider, Suite 100 Conway, Arkansas 72032
Re:  Home Bancshares, Inc.
Form 10-K for Fiscal Year Ended December 31, 2009
Filed March 5, 2010 Form 10-K for Fiscal Year Ended December 31, 2010 Filed March 10, 2011 Form 10-Q for Fiscal Quarter Ended March 31, 2011 Filed May 6, 2011 File No. 000-51904
Dear Mr. Sims:
We have reviewed your response to our letter dated February 28, 2011 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2010

Allowance for Loan Losses, page 72

1. We note your response to comment 10 from our letter dated July 29, 2010 and the revised disclosures provided on page 62 of your Form  10-Q for the period ended September 30,
2010 and page 73 of your Form 10-K for the period ended December 31, 2010.  Specifically, please tell us in further detail a nd revise your future filings to clarify what
would constitute an existing appraisal bei ng outdated in addition to how you determine
that significant market changes have occurr ed as either of these would require a new

Mr. C. Randall Sims
Home Bancshares, Inc.
May 26, 2011 Page 2
appraisal. Additionally, please tell us and revise your future filings to disclose the following:

• The typical timing surrounding the recogni tion of a collateral dependent lending
relationship and respective loans as nonpe rforming, when you order and receive an
appraisal, and the subsequent recognition of  any provision or related charge-off. In
this regard, tell us if there have been any significant time lapses  during this process;
• In more detail, the procedures you perform to monitor these loan s between the receipt
of an original appraisal and the updated appraisal;
• Whether you have charged-off an amount diffe rent from what was determined to be
the fair value of the collateral as presente d in the appraisal for any period presented.
If so, please tell us the amount of the difference and corresponding reasons for the
difference, as applicable; and
• How you account for any partially charged-o ff loans subsequent to receiving an
updated appraisal. In this regard, specifi cally tell us your policies regarding whether
or not these loans return to performing or remain non-perf orming status, in addition to
whether or not any of the terms of the orig inal loans have been modified (e.g. loan
extension, changes to in terest rates, etc).

Charge-offs and Recoveries, page 73

2. We note your disclosure revisions and res ponse as a result of comments five, six, and
seven of our letter dated February 28, 2011.  We also note that you have not completely
responded to our original comments. Speci fically as it relates to your Arkansas
relationship that resulted in a $23 million ch arge-off during the fourth quarter of 2010,
please provide for us a detailed response for each current or previous loan to this borrower and/or relationship and providing the following:

• The relevant origination information (amount, type of loan, date originated, collateral
support, borrower guarantees, etc.) for all of  the 21 loans outstanding at the time the
Individual Borrower became a related party;
• Subsequent performance each of these lo ans (i.e. payment activity, loan-to-value
statistics, etc.) and the procedures you performed to monitor each of these loans on a quarterly basis;
• Whether there were any previous extensions  of credit or modifications of original
terms to any current or prior loans, as appli cable. If so, please provide us with a detail
of these loans and related terms, the underlying reasons for the extensions or
modifications, past and current payment/perfo rmance history, in addition to any other
information deemed necessary;
• The procedures you performed to monitor th is borrower and relationship to ensure
that they would be able to repay all amounts due. In this regard and noting that the Individual Borrower was previously a relate d party, please provide us with additional
background information related to this I ndividual Borrower du ring the prior two

Mr. C. Randall Sims
Home Bancshares, Inc.
May 26, 2011 Page 3
fiscal years ended December 31, 2010 that culm inated in your decision in the fourth
quarter of 2010 to record a $23 million charge-off of related to this borrower; and
• We note that in the fourth quarter of 2010, you obtained reappraisals of collateral
supporting the real estate loans to this borro wer. Please provide us  with a timeline of
all previous appraisals obtained, the resu lting valuations, and any other information
necessary for a complete understanding.
Please ensure that your response will allow for a complete understandi ng of the totality of
the current and previous loans to this borro wer and relationship and will provide a time
line of events that led to your decision to  record $23 million in charge-offs during the
fourth quarter of 2010 as oppos ed to a previous period.

3. We also note from your response to comments five, six, and seven from our letter dated
February 28, 2011 that during December 2010 management was advised by counsel of a substantial change in circumstances regarding the collectability of pl edged receivables of
which you were previously unaware of th at undermined the Individual Borrower’s
position with respect to his entitlement to the requested fees. Ot her than your initial
review of the Settlement Receivables sche dule provided by this borrower at the time the
loan was made and subsequent monthly discus sions had with this borrower regarding the
status of these cases, please tell us and explain in further detail if you performed any other procedures (i.e. lega l opinion(s) by your outside counsel) to corroborate and
substantiate the likelihoo d of these collections.
 Non-GAAP Financial Measurements, page 85

4. We note you present Diluted Cash Earnings Per Share as a non-GAAP  measure. Please
tell us how this measure complies with Question 102.05 of the SEC’s Compliance & Disclosure Interpretations (C &DI’s) and Accounting Series Release No. 142 as it appears
to be a non-GAAP liquidity measure presented on a per share basis. Please remove this
non-GAAP measure in all future filings or te ll us why you believe it is not prohibited.

5. As a related matter and to the extent you can  support these Non-GAAP  measures, please
revise future filings to use a different title  to more accurately describe Diluted Cash
Earnings Per Share, Cash Return on Aver age Assets, and Cash Return on Average
Tangible Equity. While these measures excl ude intangible amortization, they include
certain non-cash items that impact net inco me (provision for loan loss, depreciation,
amortization of mortgage servicing rights, etc.).

Note 2. Business Acquisitions, page 105

6. We note that during 2010 you participated in five FDIC assisted tran sactions.  We also
note disclosure on page 70 that all covered loans acquired in these transactions were deemed to be covered impaired loans. In order to further understa nd, please tell us and
revise your footnotes in future filings to provide an expanded discussion of how you

Mr. C. Randall Sims
Home Bancshares, Inc.
May 26, 2011 Page 4
applied ASC 310-30 to all of the loans acquired in each of your acquisitions in addition to
addressing the following:

• Separately identify your credit impaired pur chased loans that were subject to ASC
310-30 from your non-credit impaired purchased  loans that were not subject to ASC
310-30.
• We note disclosure on page 102 that the acq uired loans were grouped into pools based
on common risk characteristic s. Please tell us the speci fic loan characteristics you
identified which allowed you to segregate the acquired loans into pools for accretion
and impairment testing purposes. Tell us how many pools you created and the basis for
segregation. Identify whether performing and nonperforming loans were separately
segregated.
• Tell us the amount of loans that were pe rforming versus nonperforming as of the
acquisition date for each loan category.
• Please tell us the specific information you reviewed in order to determine that you
would not be able to collect all contract ually required payments pursuant to ASC 310-
30-05.
• Discuss and quantify the impact of purchase  price adjustments made in subsequent
periods to the extent they are material as we note on page 106 that fair value estimates are subject to change for up to one year af ter the closing date of the acquisition as
additional information relative  to closing date fair va lues become available.
 Note 4. Loans Receivable Not Covered by Loss Share and Allowance for Loan Losses, page 123

7. We note your table detailing the activity in th e allowance for possible loan losses by loan
type on page 123.  Due to the different cr edit risks and underlying collateral for your
commercial real estate non-fa rm/non-residential as compared  to your construction/land
development loan portfolios, please revise this table in future filings to separately disclose these two classes of financing receiv ables within this tabl e. Please provide us
with your proposed disclosure as of  March 31, 2011 and December 31, 2010.

8. As a related matter, please also revise the tabl e on page 123 in future filings to disclose
both the balance of your allowance for possible loan losses and your recorded investment in financing receivables by impairment met hod (e.g. collectively evaluated, individually
evaluated, acquired with deteriorated credit quality) for each loan portfolio segment. Refer to ASC 310-10-50-11B(g) and (h) and th e example disclosure in ASC 310-10-55-7
for guidance.

9. Please revise your aging analysis for your non-covered loan portfolio on page 124 in
future filings to further breakout the amount s included in the 30-89 days past due bucket
into loans past due 30-59 days and loans past due 60-89 days. Please refer to 310-10-55-
9.

Mr. C. Randall Sims
Home Bancshares, Inc.
May 26, 2011 Page 5
10. We note your disclosures on page 124 that as of December 31, 2010 and 2009 you had $57.3 million and $35.2 million, respectively, in rest ructured non-covered loans. We also
note that most of these credits are where borro wers have continued to pay as agreed but
negotiated a lower interest ra te due to general economic pr essures rather than credit
specific pressures. Please revise your futu re filings to further disaggregate your non-
restructured loans by loan type and concessi on granted as we note disclosure on page 68
that you may either reduce the monthly payment and/or interest rate for generally about
three to twelve months.

11. We note your disclosure on page 125 that in terest recognized on non-covered impaired
loans during the year ended December 31, 2010 was $4.5 million. Please revise your future filings to include this information in your table on page 125 disaggregated by class of financing receivable pursuant to  ASC 310-10-50-15(c)(2) and ASC 310-10-55-10.
Additionally, please also disclose the amount of interest in come recognized using a cash-
basis method, as applicable, pursu ant to ASC 310-10-50-15(c)(3).

12. As a related matter, please also revise future  filings to disclose the amount of interest
income that represents the change in present value attributable to the passage of time or disclose that you recognize this amount as  bad-debt expense. Refer to ASC 310-10-50-
19.

13. We note the qualitative disclosures of your ri sk ratings as disclosed on page 126 but that
you only provide qualitative disclosures rela ted to your classified loans on page 127.
Since you disclose that management tracks certa in credit quality indicators such as the
risk ratings of loans, please revise your future filings to include quantitative disclosures
for all of your risk rated loans (i.e. Risk ratings 1-5) in your table on page 127. Please
refer to ASC 310-10-50-29 and ASC 310-10-55-8. Please also provide us with your proposed disclosures as of March 31, 2011.
14. We note your disclosure on page 127 that you have established minimum dollar amount
thresholds for loan impairment testing. Please te ll us and revise future filings to explicitly
disclose your policy for determining whic h loans are individually assessed for
impairment. Refer to ASC 310-10-50-15(d).

15. Please revise future filings to disclose your  policy for recognizing interest income and
how cash receipts are recorded on impaired loans. Refer to AS C 310-10-50-15(b).
 Note 5. Loans Receivable Covered by FDIC Loss Share, page 127

16. We note disclosure of the aging analysis of your covered loan portfolio as of December
31, 2010 on page 128. Please note that this disclo sure is not required for loans acquired
with deteriorated credit quali ty pursuant to ASC 310-10-50-5A. As a result, please either
remove this disclosure from your future filings or revise to further clarify your current disclosure. Specifically, consider disclosing how these acquired loans are determined to

Mr. C. Randall Sims
Home Bancshares, Inc.
May 26, 2011 Page 6
 be current as compared to past due taken into  consideration that these loans are accounted
for on a pooled basis and considered to be performing, in addition to any other
information necessary for a complete understanding.

Note 20. Financial Instruments, page 140

17. We note your disclosure on page 140 that your non-covered impaired loans for which
appraisals of underlying collatera l are obtained are considered to be Level 3 valuations as
compared to your foreclosed assets held for sale for which valuations are periodically
performed by management are considered to be Level 2. Please tell us and revise your
future filings to further explain why there ar e differing levels of fair values for each of
these financial assets.

You may contact John A. Spitz, Staff Accountant, at (202) 551-3484 or me at (202) 551-
3492 with any other questions.
Sincerely,

John P. Nolan Senior Assistant Chief Accountant