SecProbe.io

CORRESP
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corresp

John K. Baker

W. Christopher Barrier

Sherry P. Bartley

Steve Bauman

R. T. Beard, III

C. Douglas Buford, Jr.

Burnie Burner1

Frederick K. Campbell2

Michelle H. Cauley

Charles B. Cliett, Jr.3

Ken Cook

Elisabeth S. DeLargy4

Doak Foster2

Byron Freeland

Allan Gates2

Kathlyn Graves

Harold W. Hamlin

Jeffrey W. Hatfield

L. Kyle Heffley

Donald H. Henry

M. Samuel Jones III

John Alan Lewis

Walter E. May

Lance R. Miller

Stuart P. Miller

T. Ark Monroe, III2

Marshall S. Ney

Anne S. Parker

Larry Parks1

Lyn P. Pruitt

Christopher T. Rogers

Jeffrey L. Singleton

Derrick W. Smith2

Stan D. Smith

Marcella J. Taylor

Jeffrey Thomas2

Nicholas Thompson2

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

Walter G. Wright, Jr.

Leigh Anne Yeargan

425 West Capitol Avenue, Suite 1800

Little Rock, Arkansas 72201-3525

Telephone 501-688-8800

Fax 501-688-8807

 Trav Baxter

Courtney C. Crouch, III

5Jenny T. Garrett

Alex T. Gray

Regan P. Gruber

John K. Harriman

6Delena c. Hurst

Ben D. Jackson

Margaret A. Johnston

Tony Juneau

Cristina S. Monterrey

Valerie D. Nation

Jeffrey L. Spillyards

Zachary T. Steadman

7Jamie Metz Sweeney

Mary Catherine Wood

    Counsel

1Richard W. Alexander

Robert C. Balfe

8Heather M. Bell

9Catherine M. Corless

Jeffrey H. Dixon

10Jill Grimsley Drewyor

11Anton L. Janik, Jr.

12Bruce McCandless III

Todd L. Newton

Jennifer R. Pierce

13Julie M. Pomerantz

1Kathy Y. Reyes

14Barry G. Skolnick

Shannon S. Smith

Of Counsel

Joseph W. Gelzine

15Hermann Ivester

2H. Maurice Mitchell

John S. Selig

    Jean D. Stockburger

    Richard A. Williams

Writer’s Direct Dial

501-688-8866

June 24, 2011

    1 Only Admitted in Texas

2 Admitted in District of Columbia and Arkansas

3 Admitted in Arizona, Texas and Arkansas

4 Only Admitted in Tennessee and Texas

5 Admitted in Louisiana and Arkansas

6 Admitted in Texas, Colorado and Arkansas

7 Admitted In Florida, Virginia and Arkansas

8 Admitted in California and Arkansas

9 Only Admitted in Tennessee

10 Admitted in Oklahoma 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 New York

15 Admitted in the U.S. Patent

and Trademark Office and Arkansas

All Others Admitted Only in Arkansas

Mr. John P. Nolan

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    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. Nolan:

     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 May 26, 2011. 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 Fiscal Year Ended December 31, 2010

Allowance for Loan Losses, page 72

Mitchell,
Williams, Selig, Gates & Woodyard, P.L.L.C. | Attorneys at Law

Little Rock•Rogers•Austin | MitchellWilliamsLaw.com

Mr. John P. Nolan

United States Securities and Exchange Commission

June 24, 2011

Page 2

    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 and revise your future filings to clarify what would constitute an
existing appraisal being outdated in addition to how you determine that significant market
changes have occurred as either of these would require a new appraisal. Additionally, please
tell us and revise your future filings to disclose the following:

    •

    The typical timing surrounding the recognition of a collateral dependent lending
relationship and respective loans as nonperforming, 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;

     Response: We do not consider an appraisal outdated simply due to the passage of time.
However, if market or other conditions have deteriorated and we believe that the current market
value of the property is not within 20% of the appraised value, we will consider the appraisal
outdated and order a new appraisal for the impairment analysis. The recognition of any provision
or related charge-off on a collateral dependent loan is either through annual credit analysis or,
many times, when the relationship becomes delinquent. If the borrower is not current, we will
update our credit and cash flow analysis to determine the borrower’s repayment ability. If we
determine this ability does not exist and it appears that the collection of the entire principal
and interest is not likely, then the loan could be placed on non-accrual status. In any case,
loans are classified as non-accrual no later than 105 days past due. If the loan requires a
quarterly impairment analysis, this analysis is completed in conjunction with the completion of the
analysis of the adequacy of the allowance for loan and lease losses (“ALLL”). Any exposure
identified through the impairment analysis is shown as a specific reserve on the individual
impairment analysis tab of the ALLL worksheet. If it is determined that a new appraisal is
required, it is ordered and will be taken into consideration during the next completion of the
impairment analysis.

    •

    In more detail, the procedures you perform to monitor these loans between the
receipt of an original appraisal and the updated appraisal;

     Response: Between the receipt of the original appraisal and the updated appraisal, we monitor
the loan’s repayment history and subject the loan to examination by our internal loan review. If
the loan is over $1.0 million, our policy requires an annual credit review. In addition, we update
all financial information and calculate the global repayment ability of the borrower/guarantors.

Mr. John P. Nolan

United States Securities and Exchange Commission

June 24, 2011

Page 3

    •

    Whether you have charged-off an amount different from what was determined to be
the fair value of the collateral as presented 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

     Response: We have not charged off an amount less than what was determined to be the fair
value of the collateral as presented in the appraisal for any period presented. However, in
estimating the net realizable value of the collateral, management may deem it appropriate to
discount the appraisal based on the applicable circumstances. In such case, the amount charged off
may result in loan principal outstanding being below fair value as presented in the appraisal.

    •

    How you account for any partially charged-off loans subsequent to receiving an
updated appraisal. In this regard, specifically tell us your policies regarding
whether or not these loans return to performing or remain non-performing status, in
addition to whether or not any of the terms of the original loans have been modified
(e.g. loan extension, changes to interest rates, etc).

     Response: Loans partially charged-off are placed on non-accrual status until it is proven
that the borrower’s repayment ability with respect to the remaining principal balance can be
reasonably assured. This is usually established over a period of 6-12 months of timely payment
performance.

     We will revise our disclosures under “Allowance for Loan Losses” in our future filings to
include the information described above in response to Comment 1 as requested.

Charge-offs and Recoveries, page 73

    2.

    We note your disclosure revisions and response 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. Specifically as it relates to your Arkansas relationship that resulted
in a $23 million charge-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 loans (i.e. payment activity, loan-to-value
statistics, etc.) and the procedures you performed to monitor each of these loans on a
quarterly basis;

Mr. John P. Nolan

United States Securities and Exchange Commission

June 24, 2011

Page 4

    •

    Whether there were any previous extensions of credit or modifications of
original terms to any current or prior loans, as applicable. 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/performance history, in addition
to any other information deemed necessary;

    •

    The procedures you performed to monitor this 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 related party, please provide us with additional
background information related to this Individual Borrower during the prior two fiscal
years ended December 31, 2010 that culminated 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 borrower. Please provide us with a timeline
of all previous appraisals obtained, the resulting valuations, and any other
information necessary for a complete understanding.

    Please ensure that your response will allow for a complete understanding of the totality of
the current and previous loans to this borrower 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 opposed to a previous period.

    Response: Please see the Supplemental Information provided pursuant to Rule 12b-4.

    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 pledged receivables of which you were
previously unaware of that undermined the Individual Borrower’s position with respect to his
entitlement to the requested fees. Other than your initial review of the Settlement
Receivables schedule provided by this borrower at the time the loan was made and subsequent
monthly discussions 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. legal opinion(s) by
your outside counsel) to corroborate and substantiate the likelihood of these collections.

    Response: Please see Exhibit B to the Supplemental Information provided pursuant to Rule
12b-4.

Mr. John P. Nolan

United States Securities and Exchange Commission

June 24, 2011

Page 5

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 tell us why you believe it is not prohibited.

     Response: Because of our level of intangible assets and related amortization expenses,
management believes the non-GAAP measure is useful in measuring the financial performance of the
Company. Diluted Cash Earnings Per Share does not reflect a non-GAAP liquidity measure presented
on a per share basis. Diluted Cash Earnings Per Share represents diluted earnings per share
excluding intangible amortization. We will revise the title of this non-GAAP measurement to
Diluted Earnings Per Share Excluding Intangible Amortization.

    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 Average Assets, and Cash Return on Average Tangible Equity. While these
measures exclude intangible amortization, they include certain non-cash items that impact net
income (provision for loan loss, depreciation, amortization of mortgage servicing rights,
etc.).

     Response: We agree using the title “Cash” could be confusing to the reader of the
financial statements. Thus, we will change the titles of the referenced non-GAAP measurements in
future filings as follows:

    •

    “Diluted Cash Earnings Per Share” will be changed to “Diluted Earnings Per Share
Excluding Intangible Amortization.”

    •

    “Cash Return on Average Assets” will be changed to “Return on Average Assets
Excluding Intangible Amortization.”

    •

    “Cash Return on Average Tangible Equity” will be changed to “Return on Average
Tangible Equity Excluding Intangible Amortization.”

Note 2. Business Acquisitions, page 105

    6.

    We note that during 2010 you participated in five FDIC assisted transactions. 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 understand, please tell us and revise your
footnotes in future filings to provide an expanded discussion of how you

Mr. John P. Nolan

United States Securities and Exchange Commission

June 24, 2011

Page 6

    applied ASC 310-30 to all of the loans acquired in each of your acquisitions in
addition to addressing the following:

     Response: Certain loans acquired with deteriorated credit quality did not meet the scope of
ASC 310-30 due to cash flows and prepayments not being able to be effectively estimated. The
discounts on these loans are recognized using the effective interest method. These loans consisted
primarily of revolving credit lines, credit cards and other open ended consumer loans. The balance
of these loans is not material.

    •

    Separately identify your credit impaired purchased loans that were subject to ASC
310-30 from your non-credit impaired purchased loans that were not subject to ASC
310-30.

     Response: We determined it was not material to disclose the amount of credit impaired
purchased loans that were not subject to ASC 310-30. This amount represented only approximately
3.8% of the total acquired loans on acquisition date.

    •

    We note disclosure on page 102 that the acquired loans were grouped into pools based
on common risk characteristics. Please tell us the specific 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.

     Response: Performing and non-performing acquired loans were separately segregated. During
the acquisition period, the acqui