May 5, 2005


Mail Stop 4-8

Marlin L. Mosby III
Executive Vice President and Chief Financial Officer
First Horizon National Corporation
165 Madison Avenue
Memphis, Tennessee 38103

Re:	First Horizon National Corporation Form 10-K
	Filed March 14, 2005
	File No. 001-15185

Dear Mr. Mosby:

      We have reviewed your filing and have the following
comments.
We have limited our review to only the issues raised in our
comments.
Where indicated, we think you should revise your document in
response
to these comments in future filings.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In your response, please provide us with your
proposed
disclosures.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Summary of Significant Accounting Policies - page 60
1. Please revise your SFAS 133 derivative disclosures as follows:
* Clearly describe the specific methodology used to evaluate both
prospective and retrospective hedge effectiveness for each hedging
relationship (for example, the pipeline and the warehouse, MSR`s,
interest-only securities);
* Disclose how often hedge effectiveness tests are performed;
* Quantify and disclose where on the balance sheet and income
statement you classify your SFAS 133 qualifying fair value hedges
and
related hedged items for each major hedging relationship.
2. Specifically related to your fair value hedges of MSR,
supplementally tell us in detail the following:
* The significant components of servicing income in your table on
page 10.  Specifically tell us the gross amount of hedge
gains/losses
offset by the change in fair value of the hedged MSR;
* How you apply paragraph 21 of SFAS 133;
* How you measure both prospective and retrospective hedge
effectiveness of this hedging relationship.  For instance, how do
you
calculate the change in the fair value of your MSR related to
changes
in the benchmark interest rate;
* We note on page 41, that you do not specifically hedge the
change
in fair value of MSR attributed to unanticipated prepayments
(representing the difference between actual prepayment experience
and
estimated prepayments derived from a model).
a. How you calculate the change in fair value related to
unanticipated prepayments;
b. How you include the effect of unanticipated prepayments on the
fair value of MSR in your prospective and retrospective
effectiveness
calculations.
Please reference the applicable GAAP literature that supports your
policies.
3. Please revise to disclose how you apply paragraph 27 of SFAS
133
to your MSR impairment tests.
4. Please revise to disclose if you use different stratification
criteria for your MSR impairment tests and for the purposes of
grouping similar assets to be designated as a hedged portfolio in
your fair value hedges.  If you do, tell us how you consider the
fair
value hedge market value adjustments in your impairment tests.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter that keys your responses to our comments, indicates
your
intent to include the requested revisions in future filings and
provides any requested supplemental information.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Michael Volley, Staff Accountant, at (202)
551-
3437 or me at (202) 551-3851 if you have questions.

Sincerely,



Paul Cline
Senior Accountant

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Marlin L. Mosby III
First Horizon National Corporation
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