Via EDGAR

October 3, 2014

Mr. John P. Nolan

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: First Horizon National Corporation (“FHN” or “we”)

Form 10-K for Fiscal Year Ended December 31, 2013 (“2013 Form 10-K”)

Filed February 27, 2014

Dear Mr. Nolan:

We are in receipt of the letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated September 23, 2014, to Mr. William C. Losch III, Executive Vice President and Chief Financial Officer, regarding the above-referenced filing. We appreciate the Staff’s careful review of our filing and look forward to working with the Staff to resolve the Staff’s comments. For your convenience, we have included the Staff’s comment below in boldface followed by our response. As the request pertains to disclosure in future filings, our response includes an illustrative example of the future proposed disclosure enhancement. In this particular case, the proposed tables are based on recent year-end quantitative data and will be updated in our Form 10-K Filing for the period ended December 31, 2014.

Form 10-K for Fiscal Year Ended December 31, 2013

Exhibit 13

Asset Quality – Trend Analysis of 2013 compared to 2012

Table 19, page 39

1. Please expand your current disclosures in future filings to more clearly define and quantify the individual nonperforming loan components which you aggregate in this table. Additionally, in order to be fully compliant with Item III.C.1 of Guide III, please, separately present the aggregate amounts of loans in each of the following categories for the periods presented:

(a) Loans accounted for on a nonaccrual basis;

(b) Accruing loans which are contractually past due 90 days or more as to principal or interest payments; and

(c) Loans not included in above which are “troubled debt restructurings”

In this regard, provide a note to the tabular presentation to state the amount of nonaccrual troubled debt restructurings included in (a) Loans accounted for on a nonaccrual basis if not otherwise apparent.

Mr. John P. Nolan

United States Securities and Exchange Commission

October 3, 2014

Page 2

Response:

In future Annual Reports on Form 10-K, FHN will revise the disclosure that was presented in Table 19, page 39 on the Form 10-K for the Fiscal Period Ended December 31, 2013.

In order to accommodate the requested disaggregation of FHN’s nonaccrual loans into portfolio components and other requested disclosures, we anticipate presenting the following tables in our Annual Report on Form 10-K for the period ended December 31, 2014. Please note that we have re-presented, for all periods within the proposed tables below, certain of the disclosures related to loans held-for-sale accounted for under the fair value option in order to incorporate the negative fair value adjustment presented in Table 17 – Nonperforming Loans that was also in our December 31, 2013 Form 10-K.

Nonaccrual/Nonperforming Loans, Foreclosed Assets, and Other Disclosures (a) 

	December 31
(Dollars in thousands)	2013			2012			2011			2010			2009
Consumer:
Consumer real estate	$	117,598		$	64,445		$	38,776		$	35,451		$	17,900
Permanent mortgage		38,171			32,721			35,989			125,718			97,909
Credit card & other (b)		1,397			1,698			2,141			19,276			189,846
Total consumer		157,166			98,864			76,906			180,445			305,655
Commercial:
Commercial, financial, and industrial		79,759			122,600			162,229			213,993			135,464
Commercial real estate		18,101			45,570			114,965			252,467			458,311
Total commercial		97,860			168,170			277,194			466,460			593,775
Total nonperforming loans (c)		255,026			267,034			354,100			646,905			899,430
Nonperforming loans held-for-sale		61,139			51,385			46,651			41,546			19,773
Foreclosed real estate and other assets		45,753			41,767			68,885			110,536			113,709
Foreclosed real estate from GNMA loans		25,809			18,923			16,360			14,865			11,481
Total foreclosed real estate and other assets		71,562			60,690			85,245			125,401			125,190
Total nonperforming assets (d)	$	361,918		$	360,186		$	469,636		$	798,987		$	1,032,912
Troubled debt restructurings (e):
Accruing restructured loans	$	246,894		$	243,884		$	206,210		$	144,252		$	36,714
Nonaccruing restructured loans (f)		105,409			114,138			72,798			116,191			36,093
Total troubled debt restructurings (e)	$	352,303		$	358,022		$	279,008		$	260,443		$	72,807
Ratios:
Allowance to nonperforming loans in the loan portfolio		1.00	x		1.04	x		1.09	x		1.03	x		1.00	x
NPL % (g)		1.66	%		1.60	%		2.16	%		3.85	%		4.96	%
NPA% (h)		1.95	%		1.84	%		2.57	%		4.48	%		5.56	%

Certain previously reported amounts have been re-presented to be consistent with current presentation.

(a) Balances do not include PCI loans even though the customer may be contractually past due. PCI loans were recorded at fair value upon acquisition and accrete interest income over the remaining life of the loan.

(b) Nonperforming loans in this category are primarily One-time-close construction loans.

(c) FHN estimates interest income that would have been earned during 2013 was approximately $14 million if the loans had performed in accordance with their original terms.

(d) Balances do not include PCI loans or government-insured foreclosed real estate.

(e) Excludes TDRs that are classified as held-for-sale nearly all of which are accounted for under the fair value option.

(f) Amounts also included in nonperforming loans above.

(g) Nonperforming loans in the loan portfolio to total period end loans.

(h) Nonperforming assets related to the loan portfolio to total loans plus foreclosed assets exclusive of government-insured foreclosed real estate.

Mr. John P. Nolan

United States Securities and Exchange Commission

October 3, 2014

Page 3

Accruing Delinquencies and Other Credit Disclosures

	December 31
(Dollars in thousands)	2013		2012		2011		2010		2009
Loans past due 90 days or more and still accruing (a):
Consumer:
Consumer real estate	$	21,484	$	30,403	$	37,625	$	47,937	$	66,074
Permanent mortgage		6,129		9,592		12,415		29,367		59,986
Credit card & other		1,763		1,833		1,502		1,758		4,604
Total consumer		29,376		41,828		51,542		79,062		130,664
Commercial:
Commercial, financial, and industrial		1,810		422		234		182		2,856
Commercial real estate		1,078		—		—		—		4,303
Total commercial		2,888		422		234		182		7,159
Total loans past due 90 days or more and still accruing (a)	$	32,264	$	42,250	$	51,776	$	79,244	$	137,823
Loans 30 to 89 days past due	$	70,298	$	80,893	$	110,813	$	173,233	$	291,021
Loans 30 to 89 days past due — guaranteed (b)		187		47		67		3,801		76
Loans held-for-sale 30 to 89 days past due		14,538		15,333		7,591		8,646		17,524
Loans held-for-sale 30 to 89 days past due — guaranteed portion (b)		11,660		12,986		6,108		3,490		17,524
Loans held-for-sale 90 days past due		37,599		34,002		42,308		33,409		35,781
Loans held-for-sale 90 days past due — guaranteed portion (b)		35,118		31,699		36,299		26,790		32,159
Potential problem assets (c)	$	343,359	$	496,308	$	729,421	$	1,144,185	$	1,382,698

Certain previously reported amounts have been re-presented to be consistent with current presentation.

(a) Excludes loans classified as held-for-sale.

(b) Guaranteed loans include FHA, VA, and GNMA loans repurchased through the GNMA buyout program.

(c) Includes past due loans.

The proposed tables above, which disaggregate nonperforming loans and provide other requested disclosures, should be read in conjunction with similar disaggregated disclosures in other tables in our Form 10-K as of the most recent three and/or two years ended December 31. This includes for example, Table 15 – Asset Quality by Portfolio which provides the percentage that nonperforming loans comprise of each portfolio segment for the most recent 3 years; Table 20 – Troubled Debt Restructurings which disaggregates TDRs by portfolio segment and performance status; and the accrual/nonaccrual aging table within Note 4 – Loans which provides an aging schedule for both performing and nonperforming loans by portfolio class as of the most recent 2 years.

* * * * * *

First Horizon National Corporation acknowledges that it is responsible for the adequacy and accuracy of the disclosure in the filing, that 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 that it 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.

We hope our response adequately addresses the comment raised in your letter. Any questions with respect to the foregoing should be directed to the undersigned at (901)257-6223.

Sincerely,

/s/ Jeff L. Fleming

Jeff L. Fleming

Executive Vice President and Chief Accounting Officer