SecProbe.io

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

DIVISION OF
  CORPORATION FINANCE

        July 13, 2011
 Via Facsimile

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 May 26, 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.  Where we have specif ically requested a draft of your proposed disclosures in future
filings, please ensure that it clearly identifies new, revised or deleted disclo sures, as appropriate.
If you do not believe our comments apply to your facts and circumstances or do not believe an
amendment is appropriat e, 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 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 one from our letter dated May 26, 2011. You state that
you will consider an appraisal to be outdated if market or othe r conditions have deteriorated
and you believe the current market value of the property is not within 20% of the appraised

Mr. C. Randall Sims
Home Bancshares, Inc.
July 13, 2011 Page 2
 value.  Please tell us and revise your future filings to disclose the procedures you perform to
determine that the current market value has decreased at least 20%  from the original
appraisal valuation.
 2. We also note in your response to comment one  from our letter dated May 26, 2011 that if a
new appraisal is required, it is ordered and will be taken into consideration during the next
completion of the impairment analysis.  In ab sence of a completed ap praisal supporting the
underlying collateral, please tell us the policies and procedures  you perform to ensure that
you have appropriately accounted for a particul ar loan after the reque st but prior to the
receipt of the appraisal (i.e. as of period end) and consider providing an example to support
your accounting. Please also clarify what woul d constitute the next completion of the
impairment analysis in this context.
  Charge-off and Recoveries, page 73

 3. We note your responses to comments two and three from our letter dated May 26, 2011 along
with the related supplemental information provided.  As a result of the modifications
performed to many of the loan s of the Arkansas relationshi p on or about June 7, 2009, please
tell us in further detail how you determined these loans were not considered either non-
accrual, non-performing, impaired, and/or troubled debt restructurings as of this date and
subsequently, but prior to your decision to ch arge-off $23 million during the fourth quarter of
2010.  In your response, please tell us how you considered the following to support your
classification and related accounting for these loans:

 It appears that significan t reliance was placed upon the personal guarantee provided by
the Arkansas relationship despite the fact th at prior to these modifications the borrower
had well-publicized legal and business issues, which may have significantly jeopardized
the borrowers financial net worth and resulting ability to repay;
 The modifications made on June 7, 2009 provided for lowered interest rates, interest-only
terms, and extensions of maturity dates.  Please tell us whether these changes were
deemed to be market rates and terms when modified  and as a result whether you considered these terms to be concessions that  would result in these loans classified as
troubled debt restructurings;
 It appears that absent the continual use of the $1.5 million of credit (“Debt Service
Loan,” Loan No. 31 included in Exhibit A), th e remainder of the loans outstanding to the
Arkansas relationship would have become deli nquent more frequently than indicated in
your response (i.e. 10-30 days and mo re than 30 but less than 60 days);
 On July 9, 2009, you changed the loan classifica tion ratings for all of the loans to the
Arkansas borrower from a 4 (“watch”) to a 5 (“other loans especially mentioned”) and in
some cases loans were changed from a 5 to a 6 (“substandard”); and
 Despite the many modifications made to the loans to this borrower, it doesn’t appear
based upon review of Exhibit C that appraisals were always  obtained or updated to
support the current value of the underlying collateral for some of these loans.

Mr. C. Randall Sims
Home Bancshares, Inc.
July 13, 2011 Page 3

 You may contact John A. Spitz, Staff Accountant, at (202) 551-3484 or me at (202) 551-
3492 with any other questions.
Sincerely,
  /s/ John P. Nolan
John P. Nolan Senior Assistant Chief Accountant