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                           November 13, 2023

       D. Bryan Jordan
       Chief Executive Officer
       First Horizon Corporation
       165 Madison Avenue
       Memphis, Tennessee 38103

                                                        Re: First Horizon
Corporation
                                                            Definitive Proxy
Statement on Schedule 14A
                                                            Filed March 13,
2023
                                                            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 comments. Please respond to these
comments by confirming that
       you will revise your future proxy disclosures in accordance with the
topics discussed below.

       Definitive Proxy Statement on Schedule 14A filed March 13, 2023

       Pay Versus Performance, page 80

   1.                                                   You include "Net Income
Available to Common Shareholders" in column (h) of your pay
                                                        versus performance
table in lieu of net income as required by Regulation S-K Item
                                                        402(v)(2)(v). Please
ensure that you include net income, as reported in your audited
                                                        GAAP financial
statements, in column (h) for all years covered by the table. Refer to
                                                        Regulation S-K
Compliance and Disclosure Interpretations Questions 128D.08 and
                                                        128D.09. Please note
that you may voluntarily provide supplemental measures of
                                                        compensation or
financial performance, so long as any additional disclosure is clearly
                                                        identified as
supplemental, not misleading, and not presented with greater prominence
                                                        than the required
disclosure.
   2.                                                   You include Return on
Tangible Common Equity in column (i) of your pay versus
                                                        performance table. It
appears that you intend this to be your Company-Selected Measure
                                                        required pursuant to
Regulation S-K Item 402(v)(2)(vi). However, we also note your
                                                        disclosure in the
footnote to column (i) that "[f]or many years (including 2022), the
                                                        primary performance
measure used in FHN's long-term stock awards has been [Return on
                                                        Tangible Common
Equity], subject to several adjustments selected at the time of grant.
                                                        The data in column (i)
is not adjusted" (emphasis added).

                                                        Under Regulation S-K
Item 402(v)(2)(vi), your Company-Selected Measure is the
 D. Bryan Jordan
First Horizon Corporation
November 13, 2023
Page 2
         performance measure, "which in [your] assessment represents the most
important
         financial performance measure (that is not otherwise required to be
disclosed in the table)
         used by [you] to link compensation actually paid to [your] named
executive officers, for
         the most recently completed fiscal year, to company performance."
Please ensure that
         your Company-Selected Measure reflects the actual financial
performance measure you
         used to link compensation to company performance for the most recently
completed fiscal
         year. For example if, under this standard, adjusted Return on Tangible
Common
         Equity should be your Company-Selected Measure, please ensure that you
use it in future
         filings.
3.       In your "Relation of Pay to Performance" section, it does not appear
that you provide all
         of the relationship disclosures required by Regulation S-K Item
402(v)(5). Please ensure
         that you provide this required disclosure in its entirety. Although
you may provide the
         required information graphically, narratively, or a combination of the
two, this disclosure
         must be separate from the pay versus performance table required by
Regulation S-K Item
         402(v)(1) and must provide a clear description of each separate
relationship indicated in
         Regulation S-K Item 402(v)(5)(i)-(iv). Please note that it is not
sufficient to state that no
         relationship exists, even if a particular measure is not used in
setting compensation. You
         may voluntarily provide supplemental measures of compensation or
financial
         performance, so long as any additional disclosure is clearly
identified as supplemental, not
         misleading, and not presented with greater prominence than the
required disclosure.
       Please contact Marion Graham at 202-551-6521 or Charlie Guidry at
202-551-3621 with
any other questions.



FirstName LastNameD. Bryan Jordan                              Sincerely,
Comapany NameFirst Horizon Corporation
                                                               Division of
Corporation Finance
November 13, 2023 Page 2                                       Disclosure
Review Program
FirstName LastName