SecProbe.io

Mail Stop 4720
March 28, 2018

Mr. Brian S. Davis
Chief Financial Officer
Home Bancshares, Inc.
719 Harkrider, Suite 100
Conway, Arkansas 72032

Re: Home Bancshares, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 27, 2018
File No. 000-51904

Dear Mr. Davis :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2 017

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Non-GAAP Measurements, page 91

1. We note your non -GAAP presentations on page 92 of Average Contractual Yield on Loans,
Average Contractual Cost of Deposits, and Net Interest Margin exclude the impact of
purchase accounting.   It appears that disclosing financial metrics simply excluding the impact
of purchase accounting represents an individually tailored recognition and measurement
method which could result in  a misleading financial metric that violates Rule 100(b) of
Regulation G.   Please refer to Question 100.04 of the Compliance and Disclosure
Interpretations for guidance.   Therefore, in future filings, including Forms 8 -K, please do not
disclose financial m etrics that exclude the impact of purchase accounting.

Mr. Brian S. Davis
Home Bancshares, Inc.
March 28, 2018
Page 2

 2. We note your presentation of numerous non -GAAP measures labeled as “core” or providing
adjustments for “non -fundamental” and “non -core” items.   Please revise future filings to
change the name of these  non-GAAP measures and corresponding adjusted items to more
accurately reflect its content.   In this regard, the use of the word “core” or “non -fundamental”
implies you are referring to your most central or essential operations and results.   Adjusting
for merger costs and gains and for provisions for and recoveries of loan losses, etc. implies
that credit losses, credit recoveries, and acquisitions are not an inherent part of your core
operations.   We believe it would be appropriate to use a more descriptiv e title to describe
these non -GAAP measures, perhaps eliminating the use of the word “core” and “non -
fundamental” in its entirety.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwit hstanding any review, comments, action or absence of
action by the staff.

You may contact  John Spitz, Staff Accountant at (202) 551 -3484  or me at (202) 551 -
3437  with any questions.

Sincerely,

 /s/ Michael Volley

Michael Volley
Staff Accountant
Office of Financial Services