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Correspondence Letter

 Mr. Amit Pande

 Accounting Branch Chief

 United States Securities and Exchange Commission

100 F Street N.E.

 Washington, DC 20549

Re:
Home Bancshares, Inc.

 Form 10-K
for Fiscal Year Ended December 31, 2012

 Filed March 4, 2013

File No. 000-51904

 Dear
Mr. Pande:

 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. Randy Mayor dated May 16, 2013. For convenient reference, this response letter duplicates the text of the enumerated staff comment, as well as the heading
contained in your letter.

 December 31, 2012 Form 10-K

 Item 1A. Risk Factors – Because we have a concentration of exposure ., page 28

1.
We note your disclosure that you have a total of $379.4 million committed to the aggregate group of borrowers whose total debt exceeds the established in-house
lending limit of $20.0 million. Please revise future filings to disclose the highest approximate loan amount to one borrowing relationship. Please provide us a draft of your proposed disclosure that clearly identifies new or revised disclosure.

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 2

 Response: The Company has provided the disclosure of the highest approximate loan
amount to one borrowing relationship in Part I under Lending Activities on page 13 of our 2012 Form 10-K filing (the “2012 Form 10-K”). Located in the ninth sentence of the first paragraph, the existing sentence reads, “As of
December 31, 2012, the maximum amount outstanding to a single borrower was $57.8 million.”

 Item 7. Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 41

2.
Please revise future filings to present a roll forward of the FDIC indemnification asset for each period presented. Please provide us a draft of your proposed
disclosure that clearly identifies new or revised disclosure.

 Response: We propose to revise our
disclosure in response to the Staff’s comment. The draft revised disclosure is noted below. We intend to include the disclosure in Management’s Discussion and Analysis of Financial Condition and Results of Operations under the
“Acquisitions” section immediately before the “FDIC-Assisted Acquisitions – True-up” subsection. We undertake to include such revised disclosure in our future filings beginning with the quarter ended June 30,
2013. A draft of the proposed disclosure to be included our June 30, 2013 quarterly report is as follows:

 FDIC
Indemnification Asset

 In conjunction with FDIC-assisted transactions, the Company entered into loss
share agreements with the FDIC. These agreements cover realized losses on loans, foreclosed real estate and certain other assets. These loss share assets are measured separately from the loan portfolios because they are not contractually embedded in
the loans and are not transferable with the loans should the Company choose to dispose of them. Fair values at the acquisition dates were estimated based on projected cash flows available for loss-share based on the credit adjustments estimated for
each loan pool and the loss share percentages. The loss share assets are also separately measured from the related loans and foreclosed real estate and recorded as FDIC indemnification assets on the Consolidated Balance Sheets. Subsequent to the
acquisition date, reimbursements received from the FDIC for actual incurred losses will reduce the loss share assets. Reductions to expected credit losses, to the extent such reductions to expected credit losses are the result of an improvement to
the actual or expected cash flows from the covered assets, will also reduce the loss share assets. Increases in expected credit losses will require an increase to the allowance for loan losses and a corresponding increase to the loss share assets.

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 3

 The following table summarizes the activity in the Company’s FDIC indemnification
asset during the periods indicated:

 Changes in FDIC Indemnification Asset

Three Months Ended

Six Months Ended

June 30,
2013

June 30,
2012

June 30,
2013

June 30,
2012

(Dollars in thousands)

 Beginning balance

$

$
181,884

$

$
193,856

 Incurred claims for FDIC covered credit losses

(25,226
)

(37,868
)

 FDIC indemnification accretion/(amortization)

449

1,119

 Reduction in provision for loan losses:

 Benefit attributable to FDIC loss share agreements

5,332

5,332

 Ending balance

$

$
162,439

$

$
162,439

 In our annual report for the year ended December 31, 2013, the above table will appear as follows:

 Changes in FDIC Indemnification Asset

Years Ended

December 31,
2013

December 31,
2012

(Dollars in thousands)

 Beginning balance

$

$
193,856

 Incurred claims for FDIC covered credit losses

(61,933
)

 FDIC indemnification accretion/(amortization)

1,721

 Reduction in provision for loan losses:

 Benefit attributable to FDIC loss share agreements

6,002

 Ending balance

$

$
139,646

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 4

 Acquisitions: FDIC-Assisted Acquisitions-True Up, page 49

3.
Please revise future filings to disclose the amount of any liability recorded at each period end related to claw back provisions included in the purchase and
assumption agreements in connection with your FDIC-assisted transactions. Please provide us a draft of your proposed disclosure that clearly identifies new or revised disclosure.

Response: We will revise future filings to include the following sentence under the section “FDIC-Assisted
Acquisitions—True-Up” in the Management’s Discussion and Analysis of Financial Condition and Results of Operations:

 The amount of FDIC-assisted acquisitions true-up accrued at June 30, 2013 and 2012 was $X.X million and $6.8 million, respectively.

 Loan Portfolio – Loans Receivable Not Covered by Loss Share, page 60

4.
Please revise future filings to discuss the following:

a.
How your accounting for acquired non-covered loans impacts your credit metrics and trends. Specifically identify the credit metrics and trends most impacted (e.g.
the allowance for credit losses as a percentage of loans, etc.) and discuss the comparability between periods and with other institutions.

b.
Clearly disclose how you classify these loans as non-accrual, impaired, loans greater than 90 days and accruing, or as a trouble debt restructuring immediately after
acquisition. For example, discuss if these loans are considered impaired and on non-accrual status immediately after acquisition and the reasons for your determination.

Please provide us a draft of your proposed disclosure that clearly identifies new or revised disclosure.

Response to 4.a.: We will revise future filings to include the following expanded explanation of our accounting for acquired
non-covered loans as an introduction to “Table 10: Non-performing Assets Not Covered by Loss Share,” which was included on page 64 of the 2012 Form 10-K:

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 5

 We first reported non-covered loans acquired with deteriorated credit
quality in our December 31, 2012 financial statements following our acquisitions of Heritage and Premier in the fourth quarter of 2012. The credit metrics most heavily impacted by our acquisition of acquired non-covered loans with deteriorated
credit quality in our acquisitions of Heritage and Premier were the following credit quality indicators listed in Table 10 below:

•

 Allowance for loan losses for non-covered loans to non-covered loans;

•

 Non-performing non-covered assets to total non-covered assets; and

•

 Non-performing non-covered loans to total non-covered loans.

On the date of acquisition, acquired credit-impaired loans are initially recognized at fair value, which incorporates the
present value of amounts estimated to be collectible. As a result of the application of this accounting methodology, certain credit-related ratios, including those referenced above, may not necessarily be directly comparable with periods prior to
the acquisition of the credit-impaired non-covered loans and non-covered non-performing assets, or comparable with other institutions.

 Additionally, we intend to include the following as a footnote to “Table 10: Non-performing Assets Not Covered by Loss Share”:

Note: Purchased impaired non-covered loans are not classified as non-performing non-covered assets for the
recognition of interest income as the pools are considered to be performing. However, for the purpose of calculating the non-performing credit metrics presented above, the Company has included all of the non-covered loans which are contractually 90
days past due and still accruing, including those in performing pools.

 Response to 4.b.: We will revise future filings
to include after the last paragraph on page 66 of the 2012 Form 10-K the following expanded detailed explanation discussing how we classify loans:

 All non-covered loans acquired with deteriorated credit quality are considered impaired loans at the date of acquisition. Since the loans are accounted for on a pooled basis under ASC 310-30, individual
loans are not classified as impaired.

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 6

 Since the loans are accounted for on a pooled basis under ASC 310-30,
individual loans subsequently restructured within the pools are not classified as TDRs in accordance with ASC 310-30-40. For non-covered loans acquired with deteriorated credit quality that were deemed TDRs prior to the Company’s acquisition of
them, these loans are also not considered TDRs as they are accounted for under ASC 310-30.

 As of
December 31, 2012, there were no non-covered loans acquired with deteriorated credit quality on non-accrual status as a result of the loans being accounted for on the pool basis and the pools are considered to be performing for the accruing of
interest income. Also, acquired loans contractually past due 90 days or more are accruing interest because the pools are considered to be performing for the purpose of accruing interest income.

Allowance for Loan Losses, page 69

5.
As disclosed in Note 6 of your financial statements beginning on page 115, we note that non-covered loans collectively evaluated for impairment increased from $1.6
billion at December 31, 2011 to $1.9 billion at December 31, 2012. However, the allowance for loan losses allocated to these loans decreased from $18.5 million at December 31, 2011 to $15.8 million at December 31, 2012. Please
tell us in detail and revise your future filings to more comprehensively bridge the gap between trends in your allowance for loan loss metrics and loan balances for each period presented in your filing.

Please be as specific and detailed as needed to provide an investor with a clear understanding of the observed change in the credit
quality of your collectively evaluated loan portfolio and how this change, as well as any other key drivers, impacted your general allowance for loan losses. For instance, discuss trends in historical losses incorporated in your methodology and
trends observed in specific qualitative factors. Please provide us a draft of your proposed disclosure that clearly identifies new or revised disclosure.

 Response: We will revise our future filings to provide expanded disclosure in the “Allowance for Loan Losses” section of our annual reports to address the staff’s comment. The
following proposed disclosure is intended to address the specific changes from 2011 to 2012 referenced in the staff’s comment and would have been included following the “Miscellaneous Allocations” subheading on page 70 of our 2012
Form 10-K:

 Loans Collectively Evaluated for Impairment. Non-covered loans collectively evaluated for
impairment increased approximately $356.0 million for the year end December 31, 2012 from $1.59 billion at December 31, 2011 to $1.94 billion at December 31, 2012. The $356.0 million increase in non-covered loans collectively
evaluated for impairment is almost entirely related to the $340.3

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 7

million non-covered loans acquired in the acquisition of Vision Bank completed on February 16, 2012. The Company evaluated loans purchased in conjunction with the acquisition of Vision in
accordance with the provisions of FASB ASC Topic 310-20, Nonrefundable Fees and Other Costs. None of the purchased non-covered loans were considered impaired at the date of acquisition. The fair value discount is being accreted into interest
income over the weighted average life of the loans using a constant yield method. The addition to the Company’s non-covered loan portfolio of this $340.3 million in performing loans from the Vision acquisition is the primary reason for the
$356.0 million increase in loans collectively evaluated for impairment for the year end December 31, 2012.

The percentage of the allowance for loan losses for non-covered loans allocated to non-covered loans collectively
evaluated for impairment to the total non-covered loans collectively evaluated for impairment decreased from 1.16% at December 31, 2011 to 0.81% at December 31, 2012. This decrease resulted from (1) the acquisition of $340.3 million
of performing non-covered loans in the Vision acquisition noted above and (2) a continued improvement in the credit quality of the Company’s non-covered loan portfolio throughout 2012. Total non-covered loans charged off have decreased the
past three years from $64.5 million for the year ending December 31, 2010 to $14.7 million for the year ending December 31, 2011 to $10.8 million for the year ending December 31, 2012. Additionally, the percentage of non-covered loans
with risk ratings of 1, 2 or 3 has increased from 48.0% of the loan portfolio at December 31, 2011 to 51.2% at December 31, 2012. This improvement in the overall credit quality is largely due to improvement experienced by the Company in
the loans to borrowers in its Florida market as the state’s real estate market conditions have begun to improve.

 Table 14:
Analysis of Allowance for Loan Losses for Non-Covered Loans, page 72

6.
We note your disclosure of the “allowance for loan losses for non-covered loans plus discount for credit losses on non-covered loans acquired to total
non-covered loans plus discount for credit losses on non-covered loans acquired.” Please consider removing this credit metric in future filings or tell us why you believe the discount for credit losses on acquired loans is relevant to
non-acquired loans in order to make this ratio meaningful. In other words, this ratio makes it appear that the discount for credit losses on acquired loans is available for credit losses on non-acquired loans.

Response: We believe this presentation is an informative number to investors, and it was not our intention to make it appear that
the discount for credit losses on acquired loans is available for credit losses on non-acquired loans. As a result, we propose to improve the disclosure by expanding it to include the components of how it is calculated. We will include the new
disclosure set forth below in “Management’s Discussion and Analysis of Financial Condition and Results of Operation” (“MD&A”) under the “Non-GAAP Financial Measurements” section.

 Mr. Amit Pande

 United States Securities and Exchange Commission

 June 11, 2013

 Page
 8

 We also plan to reference the new disclosure under “Table 14: Analysis of Allowance
for Loan Losses for Non-Covered Loans” by stating, “See ‘Management’s Discussion and Analysis of Financial Condition and Results of Operation—Table 28,’ for the non-GAAP tabular reconciliation.”

The following revised d