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425
West Capitol Avenue, Suite 1800
Little Rock, Arkansas
72201-3525
Telephone 501-688-8800
Fax 501-688-8807

    John K. Baker

    M. Samuel Jones III

    Trav Baxter

    Counsel

    Robert C. Balfe

    John Alan Lewis

    Cory D. Childs

    7Heather M. Bell

    W. Christopher Barrier

    Walter E. May

    Courtney C. Crouch, III

    8Catherine M. Corless

    Sherry P. Bartley

    Lance R. Miller

    Megan Gammill

    Jeffrey H. Dixon

    Steve Bauman

    Stuart P. Miller

    5Jenny T. Garrett

    9Jill Grimsley Drewyor

    R. T. Beard, III

    T. Ark Monroe, III2

    Alex T. Gray

    10Karen P. Freeman

    C. Douglas Buford, Jr.

    Marshall S. Ney

    John K. Harriman

    11Anton L. Janik, Jr.

    Burnie Burner1

    Anne S. Parker

    6Delena c. Hurst

    12Bruce McCandless III

    Frederick K. Campbell2

    Larry Parks1

    Ben D. Jackson

    Todd L. Newton

    Michelle H. Cauley

    Lyn P. Pruitt

    Margaret A. Johnston

    Jennifer R. Pierce

    Charles B. Cliett, Jr.3

    Christopher T. Rogers

    Tony Juneau

    13Julie M. Pomerantz

    Ken Cook

    Jeffrey L. Singleton

    Christopher A. McNulty

    14Randi Reichel

    Elisabeth S. DeLargy4

    Derrick W. Smith2

    Brian A. Pipkin

    15Barry G. Skolnick

    Doak Foster2

    Stan D. Smith

    Jeffrey L. Spillyards

    Brian A. Vandiver

    Byron Freeland

    Marcella J. Taylor

    Zachary T. Steadman

    1Tod Yeslow

    Allan Gates2

    Jeffrey Thomas2

    Mary Catherine Wood

    Kathlyn Graves

    Nicholas Thompson2

    Of Counsel

    Harold W. Hamlin

    William H.L. Woodyard, III, P.A.

    Joseph W. Gelzine

    Jeffrey W. Hatfield

    Walter G. Wright, Jr.

    16Hermann Ivester

    L. Kyle Heffley

    Leigh Anne Yeargan

    2H. Maurice Mitchell

    Donald H. Henry

    John S. Selig

    Richard A. Williams

    Writer’s Direct Dial

    1 Only Admitted in Texas

    501-688-8866

    2 Admitted in District of Columbia and Arkansas

    3 Admitted in Arizona, Texas and Arkansas

    August 26, 2010

    4 Only Admitted in Tennessee and Texas

    5 Admitted in Louisiana and Arkansas

    6 Admitted in Texas, Colorado and Arkansas

    7 Admitted in California and Arkansas

    8 Admitted in Tennessee and Arkansas

    9 Admitted in Oklahoma and Arkansas

    10 Admitted in Texas and Arkansas

    11 Admitted in Colorado and Arkansas

    12 Only Admitted in New York,

    Washington, D.C. and Texas

    13 Only Admitted in Georgia and Texas

    14 Only Admitted in Maryland

    15 Only Admitted in New York

    16 Admitted in the U.S. Patent

    and Trademark Office and Arkansas

    All Others Admitted Only in Arkansas

Mr. Michael R. Clampitt

Senior Attorney

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Home BancShares, Inc.

    Form 10-K for the year ended December 31, 2009, filed March 5, 2010

    Schedule 14A, filed March 8, 2010

    Form 10-Q for the quarterly period ended March 31, 2010, filed May 10, 2010

    File No. 000-51904

    Form 8-K, filed July 22, 2010

Dear Mr. Clampitt:

     The
following is the response of Home BancShares, Inc. (“Home
BancShares” or the “Company”) to the staff’s comments
contained in your letter to Mr. C. Randall Sims dated July 29, 2010. For convenient reference,
this response letter duplicates the text of the enumerated staff comment, as well as the heading
contained in your letter.

Form 10-K for the Fiscal Year ended December 31, 2009

Business, page 3

Overview, page 3

    1.

    Please provide to us and undertake to include in your future filings, a revised
business section as required by Item 101 of Regulation S-K, to disclose the following
information:

Mr. Michael R. Clampitt

United States Securities and Exchange Commission

August 26, 2010

Page 2

    •

    revise the first paragraph to discuss the amount of revenues, profit or loss
and total assets for each of your last three fiscal years, as required by Item
101(b) of Regulation S-K;

     Response:

We will
add in future filings the following disclosure:

    As of or for the Years Ended December 31,

    2009

    2008

    2007

    Total assets

    $
    2,684,865

    $
    2,580,093

    $
    2,291,630

    Total deposits

    1,835,423

    1,847,908

    1,592,206

    Total revenue

    162,912

    174,435

    167,519

    Net income

    26,806

    10,116

    20,445

    •

    revise the first paragraph in which you discuss the development of your
business to discuss the nature and results of any merger and the acquisition of
any amount of assets otherwise than in the ordinary course of business during
the past five years, as required by item 101(a)(1) of Regulation S-K;

     Response:

We will add in future filings the following disclosure:

     We believe that many individuals and businesses prefer banking with a locally
managed community bank capable of providing flexibility and quick decisions. The
execution of our community banking strategy has allowed us to rapidly build our
network of bank subsidiaries through acquisitions.

     Twin City Bank — In May 2000, we were the largest investor in a group that
formed a holding company (subsequently renamed TCBancorp), acquired an existing bank
charter, and relocated the charter to North Little Rock, Arkansas. TCBancorp owned
Twin City Bank, with branch locations in the Little Rock/North Little Rock
metropolitan area. In January 2005, we acquired through merger the 68% of
TCBancorp’s common stock we did not already own. The purchase brought our ownership
of TCBancorp to 100%. TCBancorp had total assets of $633.4 million, loans of $261.9
million and total deposits of $500.1
million at the effective date of the acquisition. We also assumed debt
obligations with carrying values of $20.9 million, which approximated their fair
market values because the rates being paid on the obligations were at or near
estimated current market rates. The purchase price for the TCBancorp acquisition was
$43.9 million, which consisted of approximately $110,000 of cash and the issuance of

Mr. Michael R. Clampitt

United States Securities and Exchange Commission

August 26, 2010

Page 3

4,050,878 shares (adjusted for the 8% stock dividend in 2008) of our common
stock. As a result of this transaction, we recorded goodwill of $1.1 million and a
core deposit intangible of $3.3 million.

     Marine Bank - In June 2005, we acquired Marine Bancorp, Inc., and its
subsidiary, Marine Bank, in Marathon, Florida. Marine Bank was established in 1995.
Our Chairman and Chief Executive Officer, John W. Allison, was a founding board
member and the largest shareholder of Marine Bancorp, owning approximately 13.9% of
its stock at the time of our acquisition. Marine Bank had total assets of $257.6
million, loans of $215.2 million and total deposits of $200.7 million on the date of
the acquisition. We also assumed debt obligations with carrying values of $39.7
million, which approximated their fair market values because the rates being paid on
the obligations were at or near estimated current market rates. The consideration
for the merger was $15.6 million comprised of approximately 60.5%, or $9.4 million,
in cash and 39.5%, or $6.2 million, in shares of our Class B preferred stock. As a
result of this transaction, we recorded goodwill of $4.6 million and a core deposit
intangible of $2.0 million.

     Bank of Mountain View - In September 2005, we acquired Mountain View
Bancshares, Inc., and its subsidiary, Bank of Mountain View which had total assets
of $202.5 million, loans of $68.8 million and total deposits of $158.0 million on
the date of the acquisition. The consideration for the merger was $44.1 million,
which was paid approximately 90%, or $39.8 million, in cash and 10%, or $4.3
million, in shares of our common stock. As a result of this transaction, we recorded
goodwill of $13.2 million and a core deposit intangible of $3.0 million.

     Centennial Bank - On January 1, 2008, we acquired Centennial Bancshares, Inc.
and its subsidiary, Centennial Bank. Centennial Bank had total assets of $234.1
million, loans of $192.8 million and total deposits of $178.8 million on the date of
acquisition. The consideration for the merger was $25.4 million, which was paid
approximately 4.6%, or $1.2 million in cash and 95.4%, or $24.3 million, in shares
of our common stock. In connection with the acquisition, $3.0 million of the
purchase price, consisting of $139,000 in cash and 140,456 shares (adjusted for the
8% stock dividend in 2008) of our common stock, was placed in escrow related to
possible losses from identified loans and an IRS examination. In the first quarter
of 2008, the IRS examination was completed which resulted in $1.0 million of the
escrow proceeds being released. In the fourth
quarter of 2009, approximately $334,000 of losses from the escrowed loans was
identified. After we were reimbursed 100% for those losses, the remaining escrow
funds were released. In addition to the consideration given at the time of the
merger, the merger agreement provided for additional contingent consideration to

Mr. Michael R. Clampitt

United States Securities and Exchange Commission

August 26, 2010

Page 4

Centennial’s stockholders of up to a maximum of $4.0 million, which could be
paid in cash or our common stock at the election of the former Centennial accredited
stockholders, based upon the 2008 earnings performance. The final contingent
consideration was computed and agreed upon in the amount of $3.1 million on March
11, 2009. We paid this amount to the former Centennial stockholders on a pro rata
basis on March 12, 2009. All of the former Centennial stockholders elected to
receive the contingent consideration in cash. As a result of this transaction, we
recorded total goodwill of $15.4 million and a core deposit intangible of $694,000
during 2008 and 2009.

     Investment in White River Bancshares - In January 2005, we purchased 20% of the
common stock during the formation of White River Bancshares, Inc. of Fayetteville,
Arkansas for $9.1 million. White River Bancshares owns all of the stock of Signature
Bank of Arkansas, with branch locations in northwest Arkansas. In January 2006,
White River Bancshares issued an additional $15.0 million of common stock. To
maintain our 20% ownership, we made an additional investment of $3.0 million in
January 2006. During April 2007, White River Bancshares acquired 100% of the stock
of Brinkley Bancshares, Inc. in Brinkley, Arkansas. As a result, we made a $2.6
million additional investment in White River Bancshares on June 29, 2007 to maintain
our 20% ownership. On March 3, 2008, White River Bancshares repurchased our 20%
investment in their company which resulted in a one-time gain of $6.1 million.

     In December 2008, we began the process of combining the charters of our banks
and adopting Centennial Bank as the common name. First State Bank and Marine Bank
began the process by consolidating and adopting Centennial Bank as its new name.
Community Bank and Bank of Mountain View followed and were completed in the first
quarter of 2009, and Twin City Bank and the original Centennial Bank finished the
process in June of 2009. All of our banks now have the same name, logo and charter,
allowing for a more customer-friendly banking experience and seamless transactions
across our entire banking network. We remain committed, however, to our community
banking philosophy and will continue to rely on local community bank boards and
management built around experienced bankers with strong local relationships.

    •

    revise the third paragraph in which you discuss the “broad range” of
services and customers to disclose, as required by item 101(c)(1)(i), over
62 percent of your loans are commercial real estate. Disclose revenues from
each of the two states in which you operate and the percentage of your loans
and deposits in each state; and

Mr. Michael R. Clampitt

United States Securities and Exchange Commission

August 26, 2010

Page 5

     Response:

     Although we operate our subsidiary bank in Florida and Arkansas, we believe community
banking is our only operating segment. In future filings we will expand the paragraph to
include the following:

     We are primarily engaged in providing a broad range of commercial and retail
banking and related financial services to businesses, real estate developers and
investors, individuals and municipalities through our wholly owned community bank
subsidiary — Centennial Bank (the Bank). Although the Company has a diversified
loan portfolio, at December 31, 2009 and 2008, commercial real estate loans
represented 62.1% and 59.3% of gross loans and 260.5% and 410.0% of total
stockholders’ equity, respectively. The Bank has locations in central Arkansas,
north central Arkansas, southern Arkansas, the Florida Keys and southwestern
Florida.

    •

    address any changes in your business as a result of economic conditions in
your market area and your financial condition including increases in defaults
and foreclosures, and increases in the number and changes in the terms of loan
modifications and restructurings as required by Item 101(c)(1).

     Response:

     We
will include in future filings at the end of Our Market Areas section (found at the bottom
of page 6 of the 12/31/09 10-K):

Our Arkansas market has experienced less volatility than our Florida market over the
past 3 years. In fact, the Central Arkansas geography has recently been recognized
as one of the strongest metropolitan areas in the country, which has served to
offset the weakness experienced in our Florida market. The recent national economic
downturn has led to increases in defaults and foreclosures, and increases in the
number and dollars of loan modifications primarily in the Florida market. However,
the overall effect on the strength of the Company has been limited since the
non-covered Florida loan portfolio only consists of 16.2% of total non-covered loans
as of 12/31/09.

Lending Activities, page 7

    2.

    Please provide to us and undertake to include in your future filings, revised
disclosure as follows:

Mr. Michael R. Clampitt

United States Securities and Exchange Commission

August 26, 2010

Page 6

    •

    disclose the amount of subprime, “alt A” loans, interest-only and option
adjustable rate loans;

     Response:

              We do not originate and retain subprime, “alt-A” loans, interest-only and option
adjustable rate mortgage loans. Therefore, we do not believe
additional disclosure in our future filings is necessary.

    •

    disclose the amount of loans to entities located outside of your market
areas of Arkansas and Florida;

     Response:

              We do not have a material amount of loans located outside of our market areas of
Arkansas and Florida. Approximately 95% of our loans are located in Arkansas or Florida. Therefore, we do not believe
additional disclosure in our future filings is necessary.

    •

    revise the subsection entitled “Real Estate- Non-farm/Non-residential” to
provide significantly more detail including but not limited to explaining your
statement, in the first sentence, that these loans consist “primarily of loans
secured by real estate mortgages on income-producing properties” to disclose
the other types of loans that are included in this category;

     Response:

     This information will be revised in future filings as follows:

    Real Estate — Non-farm/Non-residential. Non-farm/non-residential loans
consist primarily of loans secured by real estate loans on income-producing
properties, such as shopping/retail centers, hotel/motel properties, office
buildings, and industrial/warehouse properties. Commercial lending on
income-producing property typically involves higher loan principal amounts,
and the re