H. MAURICE MITCHELL (1925-2011) WILLIAM H.L. WOODYARD, III (1945-2014) MICHELE ALLGOOD JOHN K. BAKER SHERRY P. BARTLEY TRAV BAXTER R. T. BEARD, III BENJAMIN D. BRENNER1 JASON T. BROWNING MICHELLE L. BROWNING JOHN S. BRYANT C. DOUGLAS BUFORD, JR. BURNIE BURNER2 FREDERICK K. CAMPBELL3 CHARLES B. CLIETT, JR.4 ADRIA W. CONKLIN5 KEN COOK COURTNEY C. CROUCH, III ELISABETH S. DELARGY6 JILL GRIMSLEY DREWYOR7 JANE W. DUKE DOAK FOSTER3	BYRON FREELAND KAREN P. FREEMAN5 ALLAN GATES3 KATHLYN GRAVES HAROLD W. HAMLIN MEGAN D. HARGRAVES L. KYLE HEFFLEY8 BEN D. JACKSON ANTON L. JANIK, JR. 9 WENDY L. JOHNSON MARGARET A. JOHNSTON M. SAMUEL JONES III JOHN ALAN LEWIS D. NICOLE LOVELL AMANDA L. MACLENNAN2 WALTER E. MAY BRUCE MCCANDLESS III10 CHRISTOPHER A. MCNULTY LANCE R. MILLER STUART P. MILLER T. ARK MONROE, III3 JENNIFER R. PIERCE BRIAN A. PIPKIN CHRISTOPHER D. PLUMLEE JULIE M. POMERANTZ11	425 WEST CAPITOL AVENUE, SUITE 1800 LITTLE ROCK, ARKANSAS 72201-3525 TELEPHONE 501-688-8800 FAX 501-688-8807	SCOTT PROVENCHER LYN P. PRUITT CHRISTOPHER T. ROGERS J. SCOTT SCHALLHORN 12BARRY G. SKOLNICK 3DERRICK W. SMITH STAN D. SMITH MANDY L. STANTON ZACHARY T. STEADMAN CLAYBORNE S. STONE 3JEFFREY THOMAS MARY CATHERINE WAY WALTER G. WRIGHT, JR. 5TOD YESLOW MATT BRUNSON 8BRYCE G. CRAWFORD 14LAUREN DILIZIA 2LANA L. FREEMAN ASHLEY L. GILL DAVID F. KOEHLER 13BETHANY N. MARSHALL 2REBECCA PATEL BRITTANY H. PETTINGILL KENDRA PRUITT	15SAINABOU M. SONKO GRAHAM C. TALLEY COUNSEL JOHN E. ALEXANDER MELISSA BANDY 16DAVID N. BLACKORBY CRAIG R. COCKRELL MORRIL H. HARRIMAN, JR 5MARTHA MCKENZIE HILL 17GINGER HYNEMAN KELLY MARCHAND 18NATHAN A. READ 2STANTON K. STRICKLAND ALBERT J. THOMAS III OF COUNSEL W. CHRISTOPHER BARRIER JOSEPH W. GELZINE DONALD H. HENRY 19HERMANN IVESTER ANNE S. PARKER JOHN S. SELIG MARCELLA J. TAYLOR RICHARD A. WILLIAMS
1 ADMITTED IN CALIFORNIA AND ARKANSAS 2 ONLY ADMITTED IN TEXAS 3 ADMITTED IN DISTRICT OF COLUMBIA AND ARKANSAS 4 ADMITTED IN ARIZONA, TEXAS AND ARKANSAS 5 ADMITTED IN TEXAS AND ARKANSAS 6 ADMITTED IN TENNESSEE AND TEXAS 7 ADMITTED IN OKLAHOMA, MISSOURI AND ARKANSAS 8 ADMITTED IN MISSOURI AND ARKANSAS 9 ADMITTED IN COLORADO AND ARKANSAS 10 ADMITTED IN DISTRICT OF COLUMBIA, NEW YORK, AND TEXAS		WRITER’S DIRECT DIAL 501-688-8866 March 29, 2017	11 ADMITTED IN GEORGIA AND TEXAS 12 ADMITTED IN NEW YORK AND PENNSYLVANIA 13 ADMITTED IN OKLAHOMA AND ARKANSAS 14 ADMITTED IN ALABAMA AND TEXAS 15 ADMITTED IN GEORGIA, NEW JERSEY, AND NEW YORK 16 ADMITTED IN ARKANSAS, ARIZONA, OREGON, AND TEXAS 17 ADMITTED IN TENNESSEE AND ARKANSAS 18 ADMITTED IN ARKANSAS, NEW JERSEY, AND PENNSYLVANIA 19 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

Office of Financial Services

United States Securities and Exchange Commission

100 F Street N.E.

Mail Stop 4720

Washington, DC 20549

Re: Home BancShares, Inc.

Form 10-K for Fiscal Year Ended December 31, 2016

Filed February 28, 2017

Form 8-K Filed January 19, 2017

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. Brian Davis, dated March 15, 2017. For convenient reference, this response letter duplicates the text of the enumerated Staff comment, as well as the heading contained in your letter.

MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C. | ATTORNEYS AT LAW

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Mr. John P. Nolan

Senior Assistant Chief Accountant

March 29, 2017

Page 2

Comments and Responses

Form 10-K

Non-GAAP Financial Measurements, page 88

1. Please tell us how you considered whether the non-GAAP measure “Allowance for loan losses plus discount for credit losses on purchased loans to total loans plus discount for credit losses on purchased loans” uses an individually tailored recognition and measurement method which could violate Rule 100(b) of Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure Interpretations for guidance.

Response: The Company acknowledges the Staff’s comment and confirms that it has reviewed and considered Rule 100(b) of Regulation G and Question 100.04 of the Compliance and Disclosure Interpretations (“C&DI’s”) updated on May 17, 2016.

The Company believes that certain non-GAAP measures and ratios disclosed in Table 32 on page 90 of the Company’s December 31, 2016 Form 10-K, when taken together with the corresponding GAAP measures and ratios, provide meaningful supplemental information regarding our “allowance for loan losses to total loans receivable ratio” and that investors benefit from referring to this non-GAAP measurement in assessing our asset quality. The non-GAAP measurement referenced in the Staff’s comments has been included in the Company’s Form 10-K as a result of questions received from investors regarding the impact of purchase accounting on the Company’s “allowance for loan losses to total loans receivable ratio.” Specifically, because of the Company’s significant number of historical acquisitions, investors have inquired how the “allowance for loan losses to total loans receivable ratio” has been impacted by the projected credit losses which were recorded as a discount on purchased loans during the fair value adjustments recognized in purchase accounting. For financial assets the Company has purchased in its acquisitions, GAAP requires a discount embedded in the purchase price that is attributable to the expected credit losses at the date of acquisition. Because the discount for credit losses on purchased loans is not applied to the allowance for loan losses, investors have indicated and the Company believes it is useful information to show the same accounting, on a non-GAAP basis, as if applied to all loans receivable, including those acquired in a business combination.

For the reasons described above, the Company believes the non-GAAP measurement identified by the Staff in its comment is currently presented in a manner that provides valuable supplemental information to help investors better understand the Company’s asset quality and is not misleading when taken together with the information accompanying such measurement. Therefore the Company believes its current presentation is in compliance with Question 100.04 of the C&DI’s and Rule 100(b) of Regulation G.

MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C. | ATTORNEYS AT LAW

MITCHELLWILLIAMSLAW.COM

Mr. John P. Nolan

Senior Assistant Chief Accountant

March 29, 2017

Page 3

The Company also respectfully notes that its disclosure regarding this non-GAAP measure was the subject of prior Staff comments dated May 16, 2013 and June 28, 2013, and the Company’s current disclosure, including Table 32 of the Company’s Management’s Discussion and Analysis of Financial Condition and Results of Operation included in its Form 10-K for the year ended December 31, 2016, is based on the Company’s responses to the Staff dated June 11, 2013 and July 5, 2013, respectively. Excerpts from the Company’s June 11, 2013 and July 5, 2013 response letters to the Staff, including the text of each applicable enumerated Staff comment and the Company’s response, are provided in Exhibits A and B, respectively, attached hereto.

Form 8-K Filed January 19, 2017 – Exhibit 99.1

2. Please revise future Form 8-K filings in which you present non-GAAP financial measures to disclose the information required in Rule 100(a) of Regulation G and Item 10(e)(1)(i) of Regulation S-K.

Response: The Company will revise its future Form 8-K filings in which it presents non-GAAP financial measures to disclose the information required in Rule 100(a) of Regulation G and Item 10(e)(1)(i) of Regulation S-K.

If you have any questions or require further information, please contact me at (501) 688-8866 or dbuford@mwlaw.com.

Sincerely,
MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C.
By	/s/ C. Douglas Buford, Jr.
	C. Douglas Buford, Jr.

CDB:dw

cc: Mr. Brian Davis

Mr. Michael Volley

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Exhibit A

Excerpt from June 11, 2013 Response Letter

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.

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 disclosure will be included in future filings:

We have $569.7 million of purchased non-covered loans, which includes $81.7 million of discount for credit losses on non-covered loans acquired at December 31, 2012. For purchased credit-impaired financial assets, GAAP requires a discount embedded in the purchase price that is attributable to the expected credit losses at the date of acquisition, which is a different approach from non-purchased-credit-impaired assets. While the discount for credit losses purchased on non-covered loans is not available for credit losses on non-purchased non-covered loans, management believes it is useful information to show the same accounting as if applied to all loans, including those acquired in a business combination. Therefore, management believes 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 is useful in evaluating our company. This calculation, which is similar to the GAAP calculation of allowance for loan losses for non-covered loans to total non-covered loans, is presented in Table 28 below.

[Table follows on next page.]

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Table 28: Allowance for Loan Losses for Non-Covered Loans to Total Non-Covered Loans

	As of December 31, 2012
	Non-Covered Loans			Purchased Non- Covered Loans			Total
	(Dollars in thousands)
Loan balance reported (A)	$	1,843,249		$	487,950		$	2,331,199
Loan balance reported plus discount (B)		1,843,249			569,667			2,412,916
Allowance for loan losses for non-covered loans (C)	$	45,170		$	—		$	45,170
Discount for credit losses on non-covered loans acquired (D)		—			81,717			81,717
Total allowance for loan losses for non-covered loans plus discount for credit losses on non-covered loans acquired (E)	$	45,170		$	81,717		$	126,887
Allowance for loan losses for non-covered loans to total non-covered loans (C/A)		2.45	%		N/A			1.94	%
Discount for credit losses on non-covered loans acquired to non-covered loans acquired plus discount for credit losses on non-covered loans acquired (D/B)		N/A			14.34	%		N/A
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 (E/B)		N/A			N/A			5.26	%

Note: Discount for credit losses on acquired loans are accounted for on a pool by pool basis and are not available to cover credit losses on non-acquired loans or other pools.

MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C. | ATTORNEYS AT LAW

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Exhibit B

Excerpt from July 5, 2013 Response Letter

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

2. We note your response to comment 6 in your letter dated June 11, 2013, and especially your statement that it is not your intention to make it appear that the discount for credit losses on acquired loans is available for credit losses on non-acquired loans. We do not believe aggregating the allowance for loan losses and the discount for credit losses on acquired loans and expressing the amount as a single credit metric is appropriate. Therefore, please remove this credit metric in future filings. We do not object to disclosing the information in the first two columns of the proposed Table 28.

Response: In the past, the Company has received comments from investors that they have trouble comparing our bank with other banks with no acquisitions. Since the purchase accounting rules are so different for originated loans versus purchased loans, this credit metric is a useful tool to help investors bridge the gap between the two sets of rules. We will remove this credit metric from Table 14: Analysis of Allowance for Loan Losses for Non-Covered Loans. However, after addressing the staff’s recommended improvements in the previous correspondence, this credit metric is now clearly labeled as to its calculation, use and availability. As a result, we believe it is appropriate to disclose this credit metric in the Non-GAAP section of our future filings.

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