<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            September 25, 2024

D. Bryan Jordan
Chairman of the Board, President and Chief Executive Officer
First Horizon Corporation
165 Madison Avenue
Memphis, TN 38103

       Re: First Horizon Corporation
           Definitive Proxy Statement on Schedule 14A
           Filed March 11, 2024
           File No. 001-15185
Dear D. Bryan Jordan:

      We have limited our review of your most recent definitive proxy statement
to those issues
we have addressed in our comment(s).

       Please respond to this letter by providing the requested information
and/or confirming that
you will revise your future proxy disclosures in accordance with the topics
discussed below. If
you do not believe a comment applies to your facts and circumstances, please
tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 93

1.     We note your disclosure under your pay versus performance table that the
amounts shown
       for your Company-Selected Measure, A-ROTCE, are shown as averages for
the three-year
       performance period ended with the relevant fiscal year. In future
filings, please ensure
       that the quantified performance information regarding your
Company-Selected Measure is
       not measured over a multi-year period. Refer to Item 402(v)(2)(vi) of
Regulation S-K
       and Regulation S-K Compliance and Disclosure Interpretation 128D.11. For
example, if,
       in your assessment, A-ROTCE represents the most important financial
performance
       measure used to link compensation actually paid to your named executive
officers, for the
       most recently completed fiscal year, to company performance, please
present the A-
       ROTCE results on a single-year basis for each individual year presented
in your pay
       versus performance table, even if you use the measure as part of a
multi-year
       compensation program.
 September 25, 2024
Page 2

2.     We note that your Company-Selected Measure, A-ROTCE, is not a financial
measure
       under generally accepted accounting principles. While Company-Selected
Measure
       disclosure is not subject to Regulation G or Item 10(e) of Regulation
S-K, for a non-
       GAAP Company-Selected Measure, you must disclose how it is calculated
from your
       audited financial statements. It is not clear from your disclosure on
page 94 how this
       number is calculated from your audited financial statements. We note in
this regard your
       reference to    certain other amounts    when describing the calculation
of    Tangible    equity
       in your A-ROTCE definition. Your tabular and related presentation should
show the
       quantified performance for the same measure selected as your
Company-Selected
       Measure for each covered fiscal year, using not only the same name, but
also the same
       calculation method. Quantified performance derived using different
adjustments from
       those used in the most recent fiscal year may not satisfy this
requirement. Please tell us
       and revise future disclosure to explain how the measure is calculated
from your audited
       financial statements. Note that incorporation by reference to disclosure
in separate filings
       will not satisfy this disclosure requirement.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Laura Nicholson at 202-551-3584 or Amanda Ravitz at
202-551-3412 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Disclosure Review
Program
</TEXT>
</DOCUMENT>
