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United States securities and exchange commission logo





                             December 21, 2022

       James M. Brogdon
       Executive Vice President, Chief Financial Officer and Treasurer
       Simmons First National Corporation
       501 Main Street
       Pine Bluff, Arkansas 71601

                                                        Re: Simmons First
National Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Form 10-Q for the
Quarterly Period Ended September 30, 2022
                                                            File No. 000-06253

       Dear James M. Brogdon:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-Q for the Quarterly Period Ended September 30, 2022

       Condensed Notes to Consolidated Financial Statements
       Note 2: Acquisitions, page 11

   1.                                                   We note your disclosure
of various acquisitions that the Company has completed during
                                                        2022 and 2021. In your
future filings, please expand to include all disclosures required by
                                                        ASC 805-10-50. For
example, we refer you to the requirements to disclose acquisition-
                                                        related costs in
accordance with ASC 805-10-50-2(f), as well as amounts of revenue and
                                                        earnings of the
acquiree since the acquisition date and supplemental pro forma
                                                        information in
accordance with ASC 805-10-50-2(h).
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       GAAP Reconciliation of Non-GAAP Financial Measures, page 77

   2.                                                   We note the Company's
adjustment for the exclusion of "Day 2 CECL Provision" in your
                                                        definition of Non-GAAP
financial measures. Please address the following:
 James M. Brogdon
Simmons First National Corporation
December 21, 2022
Page 2
                Considering the nature of your business and operations, tell us
how you evaluated the
              excluded provision expense to be a normal, recurring operating
expense of the
              Company.
                Tell us how you intend to present this measure on a consistent
basis going forward.
              For example, to the extent that there is a release of the
allowance related to the "Day
              2 CECL Provision" in a future period, tell us if the Company
intends to exclude any
              potential related gains associated with the release.
                Tell us how you considered and evaluated this adjustment as an
individually tailored
              accounting principle that is prohibited by Rule 100(b) of
Regulation G.

       In closing, 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.

       You may contact Marc Thomas at (202)551-3452 or Robert Klein at
(202)551-3847 with
any questions.



FirstName LastNameJames M. Brogdon                             Sincerely,
Comapany NameSimmons First National Corporation
                                                               Division of
Corporation Finance
December 21, 2022 Page 2                                       Office of
Finance
FirstName LastName
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