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First Horizon

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FY2021 Annual Report · First Horizon
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Table of Contents

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K 

☒

☐

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES 
EXCHANGE ACT OF 1934 THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2021 

- or -

TRANSITION REPORT PURSUANT TO SECTION 13 or 15(d) OF THE SECURITIES 
EXCHANGE ACT OF 1934 SECURITIES EXCHANGE ACT OF 1934

For the Transition period from __________ to__________

Commission File Number: 001-15185 

(Exact name of registrant as specified in its charter)

TN
(State or other jurisdiction
incorporation of organization)

165 Madison Avenue
Memphis, Tennessee
(Address of principal executive office)

62-0803242
(IRS Employer
Identification No.)

38103
(Zip Code)

Registrant’s telephone number, including area code:  901-523-4444 

Securities registered pursuant to Section 12(b) of the Act:

Title of Each Class

$.625 Par Value Common Capital Stock

Depositary Shares, each representing a 1/400th interest in
a share of Non-Cumulative Perpetual Preferred Stock, Series B

Depositary Shares, each representing a 1/400th interest in
a share of Non-Cumulative Perpetual Preferred Stock, Series C

Depositary Shares, each representing a 1/400th interest in
a share of Non-Cumulative Perpetual Preferred Stock, Series D

Depositary Shares, each representing a 1/4,000th interest in
a share of Non-Cumulative Perpetual Preferred Stock, Series E

Depositary Shares, each representing a 1/4,000th interest in
a share of Non-Cumulative Perpetual Preferred Stock, Series F

Trading 
Symbol(s)

 FHN

FHN PR B

FHN PR C

FHN PR D

FHN PR E

FHN PR F

Securities registered pursuant to Section 12(g) of the Act:   None

Name of Exchange on which Registered

New York Stock Exchange LLC

New York Stock Exchange LLC

New York Stock Exchange LLC

New York Stock Exchange LLC

New York Stock Exchange LLC

New York Stock Exchange LLC

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.  ☒ Yes ☐ 
No

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.  ☐ Yes ☒ 
No 

 
 
 
 
Table of Contents

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities 
Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such 
reports), and (2) has been subject to such filing requirements for the past 90 days.   ☒ Yes ☐ No
Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted 
pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period 
that the registrant was required to submit such files). ☒ Yes ☐ No
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller 
reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller 
reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act. 

Large Accelerated Filer
☒
Smaller reporting company ☐

Accelerated filer
Emerging Growth Company ☐  

☐   Non-accelerated filer

  ☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for 
complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  ☐
Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the 
effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) 
by the registered public accounting firm that prepared or issued its audit report. ☒
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). ☐ Yes ☒ No
At June 30, 2021, the aggregate market value of registrant common stock held by non-affiliates of the registrant was 
approximately $9.4 billion based on the closing stock price reported for that date. At January 31, 2022, the registrant had 
533,633,668 shares of common stock outstanding.

Portions of the Proxy Statement to be furnished to shareholders in connection with the Annual Meeting of shareholders 
scheduled for April 26, 2022:  Part III of this Report

DOCUMENTS INCORPORATED BY REFERENCE:

Auditor Name:

KPMG LLP 

Auditor Location:     Memphis, TN 

Auditor Firm ID: 185

 
 
 
 
TABLE	OF	CONTENTS	and	GLOSSARY

Table of Contents

ITEM

Glossary

Executive Summary of Principal Investment Risks 

Forward-Looking Statements

Part I

Item 1.  Business

Item 1A.  Risk Factors

Item 1B.  Unresolved Staff Comments

Item 2.  Properties

Item 3.  Legal Proceedings

Item 4.  Mine Safety Disclosures

Supplemental Part I Information

Part II

Item 5.  Market for the Registrant’s Common Equity, 

Related Stockholder Matters, and Issuer 

Purchases of Equity Securities

Item 6. 

[reserved]

Item 7.  Management’s Discussion and Analysis of 

Financial Condition and Results of Operations
Item 7A. Quantitative and Qualitative Disclosures about 

3

5

6

9

31

54

54

55

55

56

58

59

60

Page

ITEM

Page

Item 8.

Financial Statements and Supplementary Data

107

Item 9.

Changes in and Disagreements with Accountants 
on Accounting and Financial Disclosure

Item 9A.

Item 9B.

Item 10.

Item 11.

Item 12.

Item 13.

Item 14.

Item 15.

Item 16.

Controls and Procedures

Other Information

Part III

Directors and Executive Officers of the Registrant

Executive Compensation

Security Ownership of Certain Beneficial Owners
and Management and Related Stockholder 
Matters

Certain Relationships and Related Transactions

Principal Accountant Fees and Services

Part IV

Exhibits and Financial Statement Schedules

Form 10-K Summary

213

213

213

214

216

217

220

220

221

227

228

Market Risk

106

Signatures

MD&A	and	Financial	Statement	References:

In	this	report:	"2021	MD&A"	and	"2021	MD&A	(Item	7)"	generally	refer	to	Management’s	Discussion	and	Analysis	of	Financial	
Condition	and	Results	of	Operations,	inclusive	of	Glossary	of	Selected	Financial	Terms	and	Acronyms,	appearing	in	Item	7	
within	Part	II	of	this	report;	and,	"2021	Financial	Statements"	and	"2021	Financial	Statements	(Item	8)"	generally	refer	to	our	
Consolidated	Balance	Sheets,	our	Consolidated	Statements	of	Income,	our	Consolidated	Statements	of	Comprehensive	
Income,	our	Consolidated	Statements	of	Changes	in	Equity,	our	Consolidated	Statements	of	Cash	Flows,	and	the	Notes	to	the	
Consolidated	Financial	Statements,	all	appearing	in	Item	8	within	Part	II	of	this	report.

Glossary

The	following	is	a	list	of	common	acronyms	and	terms	used	throughout	this	report:

ACL
AFS	
AIR
ALCO
ALLL
ALM
AOCI
ASC
Associate

Allowance	for	credit	losses
Available	for	sale
Accrued	interest	receivable
Asset/Liability	Committee
Allowance	for	loan	and	lease	losses
Asset/liability	management
Accumulated	other	comprehensive	
income
FASB	Accounting	Standards	Codification
Person	employed	by	FHN

ASU
Bank
BOLI
C&I

CAS
CARES	Act

CBF
CCAR

Accounting	Standards	Update
First	Horizon	Bank
Bank-owned	life	insurance
Commercial,	financial,	and	industrial	loan	
portfolio
Credit	Assurance	Services
Coronavirus	Aid,	Relief,	and	Economic	
Security	Act
Capital	Bank	Financial
Comprehensive	Capital	Analysis	and	Review

	 3

2021 FORM 10-K ANNUAL REPORT

	
							
    
TABLE	OF	CONTENTS	and	GLOSSARY

Current	expected	credit	loss
CECL
Chief	Executive	Officer
CEO
CFPB
Consumer	Financial	Protection	Bureau
Collateralized	mortgage	obligations
CMO
First	Horizon	Corporation
Company
Corporation First	Horizon	Corporation
CRA
CRE
CRMC
DTA
DTL
EAD	
ECP
EPS
Fannie	Mae
FASB
FDIC
Federal	
Reserve
Fed
FHA
FHLB
FHN
FHNF

Community	Reinvestment	Act
Commercial	Real	Estate
Credit	Risk	Management	Committee
Deferred	tax	asset
Deferred	tax	liability
Exposure	as	default
Equity	Compensation	Plan
Earnings	per	share
Federal	National	Mortgage	Association	
Financial	Accounting	Standards	Board
Federal	Deposit	Insurance	Corporation

Federal	Reserve	Board
Federal	Housing	Administration
Federal	Home	Loan	Bank
First	Horizon	Corporation

Federal	Reserve	Board

FHN	Financial;	FHN's	fixed	income	division

Fair	Isaac	Corporation

FICO
First	Horizon First	Horizon	Corporation
FRB

Federal	Reserve	Bank	or	the	Federal	
Reserve	Board

Freddie	Mac

Federal	Home	Loan	Mortgage	Corporation

FTE
FTRESC
GAAP
GSE

Fully	taxable	equivalent
FT	Real	Estate	Securities	Company,	Inc.
Generally	accepted	accounting	principles
Government	sponsored	enterprises,	in	
this	filing	references	Fannie	Mae	and	
Freddie	Mac

HELOC

Home	equity	line	of	credit

HFS

HTM
IBKC
ISDA

IRS
LGD
LIBOR
LIHTC
LLC

Held	for	sale

Held	to	maturity

IBERIABANK	Corporation
International	Swap	and	Derivatives	
Association
Internal	Revenue	Service
Loss	given	default
London	Inter-Bank	Offered	Rate
Low	Income	Housing	Tax	Credit
Limited	Liability	Company

LMC
LOCOM
LRRD
LTV
MBS
MD&A

NAICS

NII
NM
NMTC
NPA
Non-PCD

NPL
OREO
PCAOB

PCD

PCI
PD
PM
PPP
PSU
RE
RM
ROA
ROU
RPL
SBA
SEC
SVaR
TD
TDBNA
TD-US
TD	Merger	
Agreement
Proposed	TD	
Merger
TDR
TRUP
UPB
USDA
VaR
VIE
we/us/our

Loans	to	mortgage	companies
Lower	of	cost	or	market
Loan	Rehab	and	Recovery	Department
Loan-to-value
Mortgage-backed	securities
Management’s	Discussion	and	Analysis	of	
Financial	Condition	and	Results	of	
Operations

North	American	Industry	Classification	
System
Net	interest	income
Not	meaningful
New	Markets	Tax	Credit
Nonperforming	asset
Non-Purchased	Credit	Deteriorated	
Financial	Assets
Nonperforming	loan
Other	Real	Estate-owned
Public	Company	Accounting	Oversight	
Board
Purchased	Credit	Deteriorated	Financial	
Assets
Purchased	credit	impaired
Probability	of	default
Portfolio	managers
Paycheck	Protection	Program
Performance	Stock	Unit
Real	estate
Relationship	managers
Return	on	Assets
Right	of	use
Reasonably	possible	loss
Small	Business	Administration
Securities	and	Exchange	Commission
Stressed	Value-at-Risk
The	Toronto-Dominion	Bank
TD	Bank,	N.A.
TD	Bank	US	Holding	Company
Merger	agreement	between	FHN,	TD,	TD-
US,	and	a	TD-US	subsidiary
The	merger	transactions	contemplated	by	
the	TD	Merger	Agreement
Troubled	Debt	Restructuring
Trust	preferred	loan
Unpaid	principal	balance
United	States	Department	of	Agriculture
Value-at-Risk
Variable	Interest	Entities
First	Horizon	Corporation

	 4

2021 FORM 10-K ANNUAL REPORT

    
EXECUTIVE	SUMMARY	OF	PRINCIPAL	INVESTMENT	RISKS

Table	of	Contents

Executive Summary of 
Principal Investment Risks

This	section	provides	an	executive	summary	of	the	
principal	risks	associated	with	an	investment	in	our	equity	
or	debt	securities.	Our	businesses	are	complex,	and	so	are	
the	risks	associated	with	them.	This	summary	is	not	a	
complete	statement	of	risks	a	prospective	or	current	
investor	should	consider.

• The	Economy.	Our	businesses	and	our	industry	are	

heavily	entwined	with	the	U.S.	economy.	We	tend	to	
perform	better	when	economic	conditions	are	
favorable,	and	our	performance	tends	to	be	weaker	
when	the	economy	is	weaker.	That	relationship	can	
be	quite	strong,	which	can	make	our	income	and	
other	key	performance	measures	volatile,	especially	
when	compared	with	companies	in	many	other	
industries.	The	economy	tends	to	rise	and	fall	in	a	
cyclical	manner	which	is	difficult	to	predict,	which	in	
turn	makes	our	performance	difficult	to	predict.	For	
additional	information,	see	the	Cyclicality	discussion	
within	Other	Business	Information,	which	begins	on	
page	18,	and	Risks	from	Economic	Downturns	and	
Changes	which	begins	on	page	38.

• Credit	Loss.	Our	lending	business—accounting	for	

about	half	of	our	revenues—is	critically	dependent	on	
our	clients	being	able	to	pay	us	back.	That	ability	
often	depends	on	economic	conditions,	but	many	
individual	factors	can	be	critical	as	well.	If	a	client	
defaults	on	a	loan,	generally	we	will	experience	a	
financial	loss	which	often	is	only	reduced,	not	
eliminated,	by	collateral	supporting	the	loan.	
Accounting	rules	require	us	to	evaluate	current	
expected	credit	loss	(CECL)	each	quarter,	booking	
losses	based	on	our	expectations.	That	process	can	
result	in	a	highly	volatile	pattern	of	recognizing	credit	
loss	each	quarter.	The	past	two	years	demonstrated	
this	volatility,	based	on	the	economic	and	business	
disruptions	associated	with	the	COVID-19	pandemic	in	
the	first	half	of	2020,	followed	by	several	fairly	
sudden	changes	in	business	circumstances	and	
expectations	over	the	next	18	months.	For	additional	
information,	see:	the	discussion	captioned	CECL	
Accounting	and	COVID-19	within	the	Significant	
Business	Developments	Over	Past	Five	Years	section	of	
Item	1,	which	begins	on	page	12;	Credit	Risks	
beginning	on	page	40;	and	Risks	Related	to	COVID-19	
Pandemic	beginning	on	page	42.

• Loan	Loss	vs	Loan	Profit.	Lending	generally	is	a	high-
volume,	low-margin	business.	This	means	that	we	
often	need	the	profits	from	many	loans	to	make	up	
for	losses	from	one	loan.	For	our	earnings	to	be	
strong,	we	need	to	hold	loan	losses	to	a	very	low	
level,	which	makes	our	management	of	credit	quality	

a	critical	function	for	us.	This	imbalance	between	loss	
and	profit	can	amplify	the	potential	for	volatility	in	
our	earnings.	For	additional	information,	see	Credit	
Risks	beginning	on	page	40.

• Interest	Rate	Conditions.	Interest	rates	and,	

especially,	the	shape	of	the	yield	curve,	are	critical	
drivers	of	our	profit	margin	from	lending.	If	the	yield	
curve	is	flat—with	long-term	rates	only	slightly	higher	
than	short-term	rates—our	lending	margins	shrink,	
and	so	does	our	net	interest	income.	Interest	rate	
policy	is	controlled	by	federal	agencies	and	by	market	
forces,	not	by	us.	In	2021	the	key	agency	in	the	U.S.		
announced	its	intention	to	cause	interest	rates	
generally	to	rise,	gradually	in	late	2021	and	2022.	This	
represented	a	significant	change	of	policy	compared	
with	2020.	Moreover,	by	the	end	of	2021	inflation	in	
the	U.S.	had	risen	to	levels	not	seen	in	decades,	
suggesting	the	announced	policy	shift	may	be	
executed	more	quickly	or	robustly	than	first	thought.	
In	early	2022,	that	agency	announced	details	which,	
coupled	with	market	reaction	to	date,	lead	us	to	
expect	that	the	yield	curve	will	flatten	during	the	year	
as	rates	generally	rise.	Over	half	of	our	loan	portfolio	
bears	variable	interest	rates	associated	with	short-
term	reference	rates;	those	loans	should	react	fairly	
quickly	to	agency	increases	in	short-term	rates.	For	
additional	information,	see:	the	Monetary	Policy	
Shifts	discussion	within	Significant	Business	
Developments	Over	Past	Five	Years,	which	begins	on	
page	12;	the	Cyclicality	discussion	within	Other	
Business	Information,	which	begins	on	page	18;	Risks	
Associated	with	Monetary	Events	beginning	on	page	
38;	Interest	Rate	and	Yield	Curve	Risks	beginning	on	
page	48;	and	discussion	under	the	caption	Federal	
Reserve	Policy	in	Transition	within	the	Market	
Uncertainties	and	Prospective	Trends	section	of	our	
2021	MD&A	(Item	7),	which	begins	on	page	99.

• Funding	Balance.	In	our	lending	business,	we	

aggregate	money	and	lend	it	out	at	rates	which	more	
than	cover	our	costs.	We	constantly	must	balance	our	
funding	sources	(deposits	and	borrowings)	with	our	
funding	needs	(lending).	Imbalances	tend	to	hurt	our	
earnings.	If	sources	become	too	large,	generally	we	
can	cut	back	short-term	borrowing	or	invest	the	
excess,	but	our	margins	can	be	weaker	as	a	result.	If	
sources	become	too	small,	we	might	have	to	forego	
profitable	lending	or	increase	funding	by	increasing	
deposit	or	borrowing	volumes	and	costs.	For	
additional	information,	see	Liquidity	and	Funding	
Risks	beginning	on	page	46.

	 5

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

EXECUTIVE	SUMMARY	OF	PRINCIPAL	INVESTMENT	RISKS

• Competition.	Competition	for	clients	and	talent	in	our	
industry	is	intense	and	unlikely	to	abate.	Competition	
for	clients	pressures	us	to	make	interest	rate	and	
other	concessions	on	lending	and	on	deposits,	which	
reduce	our	margins.	Competition	for	revenue-
producing	talent	is	a	key	method	of	obtaining	new	
client	relationships	in	many	parts	of	our	industry,	and	
pressures	us	to	increase	compensation	expense.	For	
additional	information,	see	Competition	beginning	on	
page	16,	and	Traditional	Competition	Risks	beginning	
on	page	33.

• Banking	Consolidation.	Since	the	advent	of	nation-

wide	branching	in	the	1980s,	the	banking	industry	has	
experienced	several	waves	of	substantial	
consolidation.	In	the	past	twenty	years,	technological	
improvements	have	allowed	institutions	to	become	
extremely	large	while	maintaining	adequate	client	
service,	and,	due	to	cost	efficiencies	associated	with	
scalable	technology,	have	rewarded	the	largest	
institutions	disproportionately,	incenting	banks	to	
grow	larger,	faster.	Consolidation	can	abruptly	change	
the	competitive	environment	in	our	markets.	In	
addition,	when	we	participate	in	consolidating	
actions,	as	we	did	in	2017	and	2020,	typically	it	
creates	internal	disruption	and	expense	for	a	time	
while	we	integrate	systems,	consolidate	branches,	
and	take	other	consolidation-related	actions.	
Moreover,	in	our	industry,	the	market	tends	to	
discount,	for	a	time,	the	stock	price	of	banks	that	
engage	in	major	mergers,	in	part	due	to	the	
transaction	and	integration	expenses	mentioned	
above	coupled	with	the	risk	that	the	combination	may	
not	achieve	management’s	strategic	or	tactical	
objectives.	For	additional	information,	see:	Significant	
Business	Developments	Over	Past	Five	Years	
beginning	on	page	12;	the	Strategic	Transactions	
discussion	within	the	Other	Business	Information	
section	which	begins	on	page	18;	and	Traditional	
Strategic	and	Macro	Risks	beginning	on	page	34.

• Industry	Disruption.	Technological	innovation,	and	
the	associated	changes	in	client	preferences,	are	
radically	transforming	our	industry	and	how	financial	
services	are	delivered	to	clients.	Keeping	pace	is	
expensive	and	difficult,	while	being	a	consistent	
innovation	leader	is	practically	impossible	for	a	bank	
our	size.	Moreover,	rapid	innovation	has	the	potential	
to	be	destructive	of	traditional	companies	in	our	

industry,	as	it	has	done	and	is	doing	in	other	
industries.	For	additional	information,	see	Industry	
Disruption	beginning	on	page	35.

• Regulated	Industry.	Our	principal	businesses	are	

heavily	regulated.	Our	two	primary	banking	regulators	
can	examine	us,	cause	us	to	change	our	business	
operations,	and	significantly	restrict	our	ability	to	
pursue	lines	of	business,	in	ways	not	applicable	to	
companies	in	most	other	industries.	We	also	have	
several	secondary	regulators,	each	with	significant	
though	less-encompassing	powers.	The	primary	
missions	of	the	regulators	are	to	protect	the	banking	
system	as	a	whole,	to	protect	the	federal	
government’s	deposit	insurance	fund	and	program,	
and	to	protect	clients;	none	exists	to	enhance	our	
profitability	or	promote	the	interests	of	our	investors.	
Moreover,	regulators	are	government	agencies,	and	
as	such	can	experience	significant	policy	changes	
when	the	elected	branches	of	government	experience	
such	changes.	For	additional	information,	see	
Regulatory,	Legislative,	and	Legal	Risks	beginning	on	
page	43.

• Security	&	Technology.	Fraud	and	theft	have	always	
been	significant	risks	for	banks;	we	experience	fraud	
and	theft	loss	every	year.	Technology	has	allowed	
fraud	and	theft	risks	to	grow	substantially.	Bad	actors	
can	impact	us	from	around	the	world,	day	or	night,	
both	directly	and	through	our	clients	or	vendors.	
Typically,	the	more	a	system	is	built	to	be	secure	and	
robust,	the	less	that	system	can	be	flexible	and	
adaptable.	Moreover,	high-security	often	can	be	
associated	with	a	sub-optimal	user	experience.	For	
additional	information,	see	Operational	Risks	
beginning	on	page	36.

• Expense	Control.	In	the	current	low-interest-rate	
environment,	banks	in	the	U.S.	are	focused	on	
reducing	operating	costs	as	much	as	possible.	For	
additional	information,	see	Operational	Risks	
beginning	on	page	36,	and	Risks	of	Expense	Control	
beginning	on	page	45.

For	a	more	complete	discussion	of	the	risks	associated	
with	our	businesses	and	operations	and	investment	in	our	
securities,	see	Item	1A—Risk	Factors,	beginning	on	page	
31.

Forward-Looking Statements

This	report	on	Form	10-K,	including	materials	incorporated	
into	it,	contains	forward-looking	statements	within	the	
meaning	of	the	Private	Securities	Litigation	Reform	Act	of	

1995	with	respect	to	FHN's	beliefs,	plans,	goals,	
expectations,	and	estimates.	Forward-looking	statements	
are	not	a	representation	of	historical	information,	but	

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2021 FORM 10-K ANNUAL REPORT

    
FORWARD-LOOKING	STATEMENTS

Table	of	Contents

instead	pertain	to	future	operations,	strategies,	financial	
results	or	other	developments.	The	words	“believe,”	
“expect,”	“anticipate,”	“intend,”	“estimate,”	“should,”	“is	
likely,”	“will,”	“going	forward,”	and	other	expressions	that	
indicate	future	events	and	trends	identify	forward-looking	
statements.	

Forward-looking	statements	are	necessarily	based	upon	
estimates	and	assumptions	that	are	inherently	subject	to	
significant	business,	operational,	economic	and	
competitive	uncertainties	and	contingencies,	many	of	
which	are	beyond	our	control,	and	many	of	which,	with	
respect	to	future	business	decisions	and	actions	(including	
acquisitions	and	divestitures),	are	subject	to	change.	
Examples	of	uncertainties	and	contingencies	include,	
among	other	important	factors:	

• the	possibility	that	the	anticipated	benefits	of	the	

IBKC	merger	will	not	be	realized	when	expected	or	at	
all,	including	as	a	result	of	the	impact	of,	or	problems	
arising	from,	the	integration	of	the	two	companies	or	
as	a	result	of	the	strength	of	the	economy	and	
competitive	factors	in	any	or	all	of	FHN’s	market	
areas;

• the	possibility	that	the	IBKC	merger	may	be	more	

expensive	to	integrate	than	anticipated,	including	as	a	
result	of	unexpected	factors	or	events;

• potential	adverse	reactions	or	changes	to	business	or	

associate	relationships	resulting	from	the	IBKC	
merger;

• global,	general	and	local	economic	and	business	
conditions,	including	economic	recession	or	
depression;

• the	potential	impacts	on	FHN’s	businesses	of	the	

COVID-19	pandemic,	including	negative	impacts	from	
quarantines,	market	declines,	and	volatility,	and	
changes	in	client	behavior	related	to	the	COVID-19	
pandemic;

• the	stability	or	volatility	of	values	and	activity	in	the	

residential	housing	and	commercial	real	estate	
markets;	

• potential	requirements	for	FHN	to	repurchase,	or	
compensate	for	losses	from,	previously	sold	or	
securitized	mortgages	or	securities	based	on	such	
mortgages;	

• potential	claims	alleging	mortgage	servicing	failures,	
individually,	on	a	class	basis,	or	as	master	servicer	of	
securitized	loans;	

• potential	claims	relating	to	participation	in	

government	programs,	especially	lending	or	other	
financial	services	programs;	

• expectations	of	and	actual	timing	and	amount	of	
interest	rate	movements,	including	the	slope	and	
shape	of	the	yield	curve,	which	can	have	a	significant	
impact	on	a	financial	services	institution;

• market	and	monetary	fluctuations,	including	

fluctuations	in	mortgage	markets;	

• the	financial	condition	of	borrowers	and	other	

counterparties;	

• competition	within	and	outside	the	financial	services	

industry;	

• the	occurrence	of	natural	or	man-made	disasters,	
global	pandemics,	conflicts,	or	terrorist	attacks,	or	
other	adverse	external	events;

• effectiveness	and	cost-efficiency	of	FHN’s	hedging	

practices;	

• fraud,	theft,	or	other	incursions	through	conventional,	

electronic,	or	other	means	directly	or	indirectly	
affecting	FHN	or	its	clients,	business	counterparties	or	
competitors;	

• the	ability	to	adapt	products	and	services	to	changing	

industry	standards	and	client	preferences;

• risks	inherent	in	originating,	selling,	servicing,	and	
holding	loans	and	loan-based	assets,	including	
prepayment	risks,	pricing	concessions,	fluctuation	in	
U.S.	housing	and	other	real	estate	prices,	fluctuation	
of	collateral	values,	and	changes	in	client	profiles;

• the	changes	in	the	regulation	of	the	U.S.	financial	

services	industry;

• changes	in	laws,	regulations,	and	administrative	

actions,	including	executive	orders,	whether	or	not	
specific	to	the	financial	services	industry;

• changes	in	accounting	policies,	standards,	and	

interpretations;

• evolving	capital	and	liquidity	standards	under	

applicable	regulatory	rules;

• accounting	policies	and	processes	require	

management	to	make	estimates	about	matters	that	
are	uncertain;	

• the	occurrence	of	any	event,	change	or	other	

circumstances	that	could	give	rise	to	the	right	of	one	
or	both	of	the	parties	to	terminate	the	TD	Merger	
Agreement;	

• the	outcome	of	any	legal	proceedings	that	may	be	
instituted	against	FHN,	TD,	or	TD-US,	including	
potential	litigation	that	may	be	instituted	against	FHN	
or	its	directors	or	officers	related	to	the	Proposed	TD	
Merger	or	the	TD	Merger	Agreement;	

• the	timing	and	completion	of	the	Proposed	TD	

Merger,	including	the	possibility	that	the	Proposed	TD	
Merger	will	not	close	when	expected	or	at	all	because	
required	regulatory,	shareholder,	or	other	approvals	
are	not	received	or	other	conditions	to	the	closing	are	
not	satisfied	on	a	timely	basis	or	at	all,	or	are	
obtained	subject	to	conditions	that	are	not	
anticipated;

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Table	of	Contents

FORWARD-LOOKING	STATEMENTS

• the	risk	that	any	announcements	relating	to	the	

Important	Other	Information

In	connection	with	the	proposed	transaction,	FHN	intends	
to	file	relevant	materials	with	the	SEC,	including	
preliminary	and	definitive	proxy	statements	on	Schedule	
14A.	

This	Annual	Report	on	Form	10-K	does	not	constitute	an	
offer	to	sell	or	a	solicitation	of	an	offer	to	buy	any	
securities	or	a	solicitation	of	any	vote	or	approval.	
SHAREHOLDERS	OF	FHN	ARE	URGED	TO	READ,	WHEN	
AVAILABLE,	ALL	RELEVANT	DOCUMENTS	(INCLUDING	ANY	
AMENDMENTS	OR	SUPPLEMENTS	THERETO)	FILED	WITH	
THE	SEC,	INCLUDING	FHN’S	PROXY	STATEMENT,	BECAUSE	
THEY	WILL	CONTAIN	IMPORTANT	INFORMATION	ABOUT	
FHN	AND	THE	PROPOSED	TRANSACTION.	

Investors	and	shareholders	will	be	able	to	obtain	a	free	
copy	of	the	proxy	statement	as	well	as	other	relevant	
documents	when	filed	with	the	SEC	without	charge	at	the	
SEC’s	website	(http://www.sec.gov).	Copies	of	the	proxy	
statement	and	the	filings	with	the	SEC	that	will	be	
incorporated	by	reference	in	the	proxy	statement	will	also	
be	available	once	filed,	without	charge,	by	directing	a	
request	to	Clyde	A.	Billings	Jr.,	First	Horizon	Corporation,	
165	Madison,	Memphis,	TN	38103,	telephone	(901)	
523-4444.

Proposed	TD	Merger	could	have	adverse	effects	on	
the	market	price	of	the	common	stock	of	FHN;

• certain	restrictions	during	the	pendency	of	the	

Proposed	TD	Merger	that	may	impact	FHN’s	ability	to	
pursue	certain	business	opportunities	or	strategic	
transactions;	

• the	possibility	that	the	Proposed	TD	Merger	may	be	

more	expensive	to	complete	than	anticipated,	
including	as	a	result	of	unexpected	factors	or	events;	

• the	diversion	of	management’s	attention	from	
ongoing	business	operations	and	opportunities	
caused	by	the	Proposed	TD	Merger;	

• reputational	risk	and	potential	adverse	reactions	or	
changes	to	business	or	employee	relationships,	
including	those	resulting	from	the	announcement	of	
the	Proposed	TD	Merger;	and

• other	factors	that	may	affect	future	results	of	FHN.

FHN	assumes	no	obligation	to	update	or	revise	any	
forward-looking	statements	that	are	made	in	this	report	
on	Form	10-K	or	in	any	other	statement,	release,	report,	
or	filing	from	time	to	time.	Actual	results	could	differ	and	
expectations	could	change,	possibly	materially,	because	of	
one	or	more	factors,	including	those	factors	listed	above	
or	presented	elsewhere	in	this	report,	or	in	those	factors	
listed	in	material	incorporated	by	reference	into	this	
report.	In	evaluating	forward-looking	statements	and	
assessing	our	prospects,	readers	of	this	report	should	
carefully	consider	the	factors	mentioned	above	along	with	
the	additional	risk	factors	discussed	in	Items	1	and	1A	of	
this	report	and	in	2021	MD&A	(Item	7),	among	others.

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Table	of	Contents

ITEM	1.	BUSINESS

PART  I

Item 1.  Business

Our Businesses

Overview

First	Horizon	Corporation	is	a	Tennessee	corporation.	We	
incorporated	in	1968,	and	are	headquartered	in	Memphis,	
Tennessee.	We	are	a	bank	holding	company	under	the	
Bank	Holding	Company	Act,	and	a	financial	holding	
company	under	the	Gramm-Leach-Bliley	Act.	Our	common	
stock	is	listed	on	the	New	York	Stock	Exchange	under	the	
symbol	“FHN.”	At	December	31,	2021,	we	had	total	
consolidated	assets	of	$89	billion.	We	provide	diversified	
financial	services	primarily	through	our	principal	
subsidiary,	First	Horizon	Bank.	The	Bank	is	a	Tennessee	
banking	corporation	headquartered	in	Memphis,	
Tennessee.	

The Bank

The	Bank	was	founded	in	1864	as	First	National	Bank	of	
Memphis.	During	2021,	through	its	various	business	lines,	
including	consolidated	subsidiaries,	the	Bank	reported	
revenues	(net	interest	income	plus	noninterest	income)	of	
approximately	$3	billion.	The	Bank	generated	a	substantial	
majority	of	First	Horizon’s	consolidated	revenue.	At	

During	2021	approximately	35%	of	our	consolidated	
revenues	were	provided	by	fee	and	other	noninterest	
income,	and	approximately	65%	of	revenues	were	
provided	by	net	interest	income.	

As	a	financial	holding	company,	we	coordinate	the	
financial	resources	of	the	consolidated	enterprise	and	
maintain	systems	of	financial,	operational,	and	
administrative	control	intended	to	coordinate	selected	
policies	and	activities,	including	as	described	in	Item	9A	of	
Part	II.

December	31,	2021,	the	Bank	had	$89	billion	in	total	
assets,	$76	billion	in	total	deposits,	and	$54	billion	in	total	
loans	and	leases	(net	of	unearned	income	and	net	of	
allowance	for	loan	and	lease	losses).	

Principal Businesses, Brands, & Locations

At	year-end	2021	our	principal	businesses	were	conducted	
mostly	under	two	or	three	brands.	Brand	integration	from	
the	IBKC	merger	was	delayed	until	February	2022,	after	
which	we	began	phasing	out	certain	brands.	Our	principal	
brands	at	year-end	are	summarized	in	Table	1.1.

At	December	31,	2021,	First	Horizon’s	subsidiaries	had	
over	500	business	locations	in	22	U.S.	states,	excluding	
off-premises	ATMs.	Most	of	those	locations	were	banking	
centers.	At	year-end,	First	Horizon	had	427	banking	
centers	in	twelve	states,	as	shown	in	Table	1.2.	

Table	1.1

Table	1.2

Principal	Businesses	&	Brands	At	Year-End

Businesses
Banking	&	financial	
services	generally

Brands
• First	Horizon	&	First	Horizon	Bank
• IBERIABANK

Fixed	income	/	
capital	markets

Mortgage	lending

• FHN	Financial

• First	Horizon	Bank
• IBERIABANK	Mortgage

Title	services

• Lenders	Title	Group

Insurance	brokerage	&	
management	services

• First	Horizon	Advisors

Wealth	management	&	
brokerage	services

• First	Horizon	Advisors
• IBERIA	Wealth	Management

Banking	Centers	at	Year-End
State
Tennessee
Florida
North	Carolina
Louisiana
Alabama
Arkansas

State
Georgia
South	Carolina
Texas
Virginia
Mississippi
New	York

#
140
83
79
57
13
12

#
12
10
8
8
4
1

Many	banking	centers	contain	special-service	areas	such	
as	wealth	management	and	mortgage	lending.	

At	year-end	2021,	First	Horizon	also	had	client-service	
offices	not	physically	within	banking	centers,	including	

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ITEM	1.	BUSINESS

Table	of	Contents

fixed	income,	title	services,	home	mortgage,	wealth	
management,	and	commercial	loan	offices.	The	largest	
groups	of	those	offices	were:	29	fixed	income	offices	in	16	
states	across	the	U.S.;	30	title	services	offices	in	Arkansas,	

Loans & Deposits

Lending	and	deposit-taking	are	core	businesses	for	us.	Our	
largest	resource	to	fund	our	lending	is	our	deposit	base.	At	
year-end	2021,	we	had	total	loans	(net	of	unearned	
income)	of	$55	billion,	total	net	loans	(net	of	unearned	
income	and	net	of	allowance	for	loan	and	lease	losses)	of	
$54	billion,	and	total	deposits	of	$75	billion.	Most	of	our	
loans	and	deposits	are	held	in	our	regional	banking	and	
specialty	banking	segments.	Most	of	our	loans	are	
commercial,	and	most	of	them	are	traditional,	unsecured	
commercial,	financial,	and	industrial	loans,	or	“C&I”	loans.	
The	other	two	major	loan	portfolios	are	secured	
commercial	real	estate	loans,	or	“CRE”	loans,	and	secured	
consumer	real	estate	loans.	Table	1.3	provides	an	
overview	of	our	loan	and	deposit	balances	at	
December	31,	2021	or	averaged	over	the	year	2021.	

Table	1.3

Loans	&	Deposits	by	Type

Deposits2
Savings

Time	deposits

Other	interest

Noninterest

	37	%

	6	%

	22	%

	35	%

Loans1
Commercial

Consumer

	79	%

	21	%

Commercial	Portfolios

C&I

CRE

	72	%

	28	%

Consumer	Portfolios
Real	estate

	92	%

Credit	card/other

	8	%
1	Percentages	at	December	31,	2021;	includes	certain	leases.
2	Percentages	of	average	deposits	for	2021.
Percentages	may	not	add	to	100%	due	to	rounding.

	Table	1.5

Tennessee,	and	Louisiana;	and	15	stand-alone	mortgage	
lending	offices	in	9	states.	First	Horizon	also	has	
operational	and	administrative	offices.	

The	 C&I	portfolio,	 more	than	half	of	total	loans,	was	$31	
billion	 on	 December	 31,	 2021.	 Within	 C&I,	 about	 26%	 of	
loans	 are	 to	 businesses	 in	 the	 financial	 services	 industry,	
including	 mortgage	 lending	 companies,	 with	 the	 rest	 in	 a	
wide	range	of	industries,	as	shown	in	Table	1.4.

Table	1.4

C&I	Loans1	by	Line	of	Business
	15	%

Mortgage	lending	companies

Finance	&	Insurance

	11	%

Real	estate	rental	&	leasing

Health	care	&	social	assistance

Accommodation	&	food	service

Manufacturing

Wholesale	trade

Retail	trade

	9	%

	8	%

	7	%

	6	%

	6	%

	5	%

Other	C&I

	33	%

1		Percentages	of	C&I	portfolio	at	December	31,	2021.
Percentages	may	not	add	to	100%	due	to	rounding.

Geographically,	a	significant	majority	of	our	loans	
originate	from	five	states:	Tennessee,	Florida,	Louisiana,	
North	Carolina,	and	Texas.	The	geographic	dispersion	of	
our	loans	varies	considerably	among	our	three	major	loan	
portfolios,	as	shown	in	Table	1.5.

C&I	Loans	($31B)1
Tennessee

Florida

Texas

North	Carolina

Louisiana

California

Georgia
All	other	states

Major	Loan	Portfolios	by	Geography
CRE	Loans	($12B)1

Consumer	RE	Loans	($11B)1

	20	%

	12	%

	10	%

	7	%

	7	%

	7	%

	5	%
	32	%

Florida

Texas

North	Carolina

Louisiana

Tennessee

Georgia

All	other	states

	26	%

	12	%

	11	%

	10	%

	9	%

	8	%

	24	%

Florida

Tennessee

Louisiana

North	Carolina

Texas

New	York

	32	%

	23	%

	10	%

	8	%

	7	%

	5	%

All	other	states

	15	%

1	Dollars	and	percentages	within	each	portfolio	at	December	31,	2021.

Further	information	regarding	deposits	and	our	other	
major	sources	of	funding	is	provided	in	Notes	9,	10,	and	
11	beginning	on	pages	154,	155,	and	156,	respectively,	
appearing	in	our	2021	Financial	Statements	(Item	8),	and	

under	the	captions	Deposits,	Short-term	Borrowings,	and	
Term	Borrowings	beginning	on	pages	85,	86,	and	86,	
respectively,	of	our	2021	MD&A	(Item	7).	Further	
information	regarding	our	loans	is	provided	in	Note	4	

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ITEM	1.	BUSINESS

Table	of	Contents

beginning	on	page	139	appearing	in	our	2021	Financial	
Statements	(Item	8),	and	under	the	captions	Analysis	of	
Financial	Condition	and	Asset	Quality,	beginning	on	pages	
70	and	73,	respectively,	of	our	2021	MD&A	(Item	7).

Business Segments

Segment	Overview

Our	financial	results	of	operations	are	reported	through	
operational	business	segments	which	are	not	closely	
related	to	the	legal	structure	of	our	subsidiaries.	As	a	
result	of	our	recent	merger	of	equals	with	IBERIABANK	
Corporation	(see	Significant	Business	Developments	over	
Past	Five	Years	in	this	Item	1	below),	we	changed	our	
segments.	Before	the	merger,	we	operated	through	four	
business	segments:	regional	banking,	fixed	income,	
corporate,	and	non-strategic.	Currently,	we	operate	
through	three	segments:	regional	banking,	specialty	
banking,	and	corporate.	In	this	report,	segment	
information	related	to	prior	periods	has	been	reclassified	
to	conform	with	current	segments.

Financial	and	other	additional	information	concerning	our	
segments—including	information	concerning	assets,	
revenues,	and	financial	results—appears	in	our	2021	
MD&A	(Item	7)	and	in	our	2021	Financial	Statements	
(Item	8),	especially	in	Note	20—Business	Segment	
Information.	Note	20	begins	on	page	178.

Regional	and	Specialty	Banking	Segments

By	far	most	of	our	loans	and	deposits	are	in	the	regional	
banking	and	specialty	banking	segments.	Similarly,	those	
segments	are	the	sources	of	most	of	our	revenues	and	
expenses.	The	two	segments	create	and	use	financial	
resources	differently,	and	they	generate	different	types	of	
revenues.	Most	notably:	regional	banking	provides	a	
majority	of	our	net	interest	income	(mainly	from	lending),	
while	specialty	banking	provides	more	noninterest	income	
(mainly	from	fees).	In	addition,	regional	banking	is	larger	
than	specialty	banking	by	many	financial	measures.	Table	
1.6	provides	high-level	financial	information	for	each	of	
those	two	segments,	highlighting	these	points.

Table	1.6	

Regional	vs	Specialty	Banking	Snapshot

(Dollars	in	millions)

2021	Average	assets

2021	Net	interest	income

2021	Noninterest	income

2021	Pretax	income

Regional

Specialty

$	 45,445	

$	 20,803	

$	 1,764	

$	

438	

$	 1,280	

$	

$	

$	

619	

597	

709	

Regional	and	Specialty	Lines	of	Business

The	principal	lines	of	business	in	the	regional	banking	
segment	are:

• commercial	banking	(larger	business	enterprises)
• business	banking	(smaller	business	enterprises)

• consumer	banking

• private	client	and	wealth	management

The	principal	lines	of	business	in	the	specialty	banking	
segment	are:

• fixed	income/capital	markets
• professional	commercial	real	estate	(Pro-CRE)

• mortgage	warehouse	lending

• asset-based	(secured)	lending

• franchise	finance

• equipment	finance

• corporate	banking

• correspondent	banking

• mortgage	origination	and	title	services

Geographically,	regional	banking's	businesses	mainly	serve	
our	traditional	markets	associated	with	our	banking	center	
footprint.	Many	of	the	businesses	within	specialty	banking	
have	much	broader	geographic	reach.	For	example:	our	
fixed	income	business	has	offices	from	Hawaii	to	
Massachusetts;	and	California	is	listed	in	Table	1.5	
primarily	because	of	specialty	banking	business	lines.	

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Table	of	Contents

Services We Provide

ITEM	1.	BUSINESS

At	December	31,	2021,	we	provided	the	following	services	
through	our	subsidiaries	and	divisions:

• trust,	fiduciary,	and	agency	services

• credit	card	products			

• general	banking	services	for	consumers,	businesses,	

• equipment	finance	services

financial	institutions,	and	governments

• fixed	income	sales	and	trading;	underwriting	of	bank-
eligible	securities	and	other	fixed-income	securities	
eligible	for	underwriting	by	financial	subsidiaries;	loan	
sales;	advisory	services;	and	derivative	sales

• mortgage	banking	services

• title	insurance	and	loan-closing	services

• brokerage	services

• correspondent	banking

• transaction	processing:	nationwide	check	clearing	

services	and	remittance	processing

• investment	and	financial	advisory	services

• mutual	fund	sales	as	agent

• retail	insurance	sales	as	agent

Information	about	the	net	interest	income	and	
noninterest	income	we	obtained	from	our	largest	
categories	of	products	and	services	appears	under	the	
caption	Results	of	Operations—2021	Compared	to	2020	
beginning	on	page	63	of	our	2021	MD&A	(Item	7).

Significant Business Developments Over Past Five Years

Selected Financial Data Past Five Years

Table	1.7	provides	selected	data	concerning	revenues,	expenses,	assets,	liabilities,	and	shareholders’	equity	for	the	past	five	
years.	

Table	1.7

SELECTED	CONSOLIDATED	FINANCIAL	DATA
(Dollars	in	millions;	financial	condition	data	shown	period-end,	as	of	December	31)

Net	interest	income $	

Provision	for	credit	losses 	
Noninterest	income 	
Net	income	available	to	common	shareholders 	
Total	loans	and	leases 	
Total	assets 	
Total	deposits 	
Total	term	borrowings 	
Total	liabilities 	
Preferred	stock	 	
Total	shareholders’	equity 	

2021

2020

2019

2018

2017

1,994	 $	
(310)	 	
1,076	 	
962	 	
54,859	 	
89,092	 	
74,895	 	
1,590	 	
80,598	 	
520	 	
8,494	 	

1,662	 $	
503	 	
1,492	 	
822	 	
58,232	 	
84,209	 	
69,982	 	
1,670	 	
75,902	 	
470	 	
8,307	 	

1,210	 $	
45	 	
654	 	
435	 	
31,061	 	
43,311	 	
32,430	 	
791	 	
38,235	 	
96	 	
5,076	 	

1,220	 $	

8	 	
723	 	
539	 	
27,536	 	
40,832	 	
32,683	 	
1,171	 	
36,047	 	
96	 	
4,785	 	

842	
(1)	
490	
159	
27,659	
41,423	
30,620	
1,218	
36,843	
96	
4,580	

Priorities & Developments

Over	the	past	five	years,	our	strategic	priorities	have	
focused	on:

• targeted	and	opportunistic	expansion	of	consumer	
and	commercial	banking	products	and	markets;

• targeted	and	opportunistic	expansion	of	commercial	

lending,	mainly	through	strategic	and	tactical	
transactions,	talent	development,	and	talent	
acquisitions;

• managing	business	units	and	products	with	a	strong	

emphasis	on	risk-adjusted	returns	on	invested	capital;

• providing	exceptional	client	service	and	experience	as	
a	primary	means	to	differentiate	us	from	competitors;	
and

• investment	in	scalable	technology	and	other	

infrastructure	to	attract	and	retain	clients	and	to	
support	expansion.

• rigorous	expense	management	with	continued	
investment	in	revenue	generating	initiatives;

Examples	of	our	implementation	of	these	priorities	
include:	

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Table	of	Contents

ITEM	1.	BUSINESS

• In	July	2020,	we	completed	a	merger	of	equals	
transaction	with	IBERIABANK	Corporation	and	
purchased	30	branches	from	Truist	Bank,	making	
2020	a	transformative	year.	See	IBKC	Merger	of	
Equals	and	30-Branch	Acquisition	in	this	Item	below	
for	additional	information.	In	February	2022,	we	
completed	the	main	systems	conversion	work	related	
to	that	merger.

• As	shown	in	Table	1.7,	the	COVID-19	pandemic	

caused	us	to	recognize	substantial	provision	for	credit	
losses	in	2020,	and	reduced	our	transaction	volume	
and	revenues.	See	the	discussion	captioned	CECL	
Accounting	and	COVID-19	within	Events	Impacting	
Year-to-Year	Comparisons,	immediately	below.	In	
2021,	a	large	portion	of	that	provision	expense	was	
effectively	reversed,	resulting	in	a	provision	credit	for	
the	year.

• The	pandemic	also	resulted	in	strong	deposit	growth	

in	2020	and	2021,	despite	interest	rates	being	
extremely	low.	We	believe	federal	assistance	and	
stimulus	programs	in	2020	and	early	2021	significantly	
bolstered	deposits	in	both	years.

• In	2017	we	merged	with	Capital	Bank	Financial	Corp.,	
which	had	$10	billion	of	total	assets	and	nearly	200	
banking	centers	in	four	southern	U.S.	states.	In	
another	2017	transaction,	we	acquired	a	national	
leader	in	trading,	securitization,	and	analysis	of	Small	
Business	Association	loans.

• We	have	made	key	talent	hires	in	critical	areas	

throughout	our	company,	with	the	main	focus	on	
organically	growing	economically	profitable	business	
lines	inside	and	outside	our	traditional	markets.

• Throughout	this	period,	but	especially	in	2021,	we	

have	pruned	and	adapted	our	physical	banking	center	
network	to	reflect	long-term	trends	in	client	usage	of	
banking	centers,	and	are	making	more	efficient	use	of	
other	physical	facilities.	Correspondingly,	we	have	
expanded	and	enhanced	our	digital	banking	products	
and	services.	These	efforts	are	expected	to	continue.

• Lending	has	been	strong	in	certain	specialty	areas,	
such	as	lending	to	mortgage	companies,	where	
demand	is	strongly	stimulated	by	the	low	interest	
rates	in	effect	during	this	period.	

Events Impacting Year-to-Year Comparisons

IBKC	Merger	of	Equals	in	2020

30-Branch	Acquisition	in	2020

In	July	2020,	we	closed	our	merger	of	equals	with	
IBERIABANK	Corporation	(“IBKC”).	IBKC	was	the	parent	
company	of	IBERIABANK	based	in	Lafayette,	Louisiana.	At	
year-end	2019,	IBKC	had	$31.7	billion	of	total	assets—
nearly	75%	of	our	size	at	that	time—and	operated	over	
190	banking	centers	in	11	states:	Louisiana,	Texas,	
Arkansas,	Tennessee,	Mississippi,	Alabama,	Georgia,	
Florida,	North	and	South	Carolina,	and	New	York.	IBKC’s	
largest	concentrations	of	banking	centers	were	in	
Louisiana	and	Florida.	We	and	IBKC	offered	many	of	the	
same	financial	services	before	the	merger,	but	IBKC	
exceeded	us	in	several	areas,	most	notably	in	equipment	
financing,	mortgage,	and	title	services.

After	closing,	our	board	expanded	to	17	directors,	of	
which	nine	are	from	legacy	First	Horizon	and	eight	are	
from	legacy	IBKC.	IBKC	shareholders	collectively	were	
issued	243	million	First	Horizon	common	shares	(on	a	net	
basis).	

Under	applicable	accounting	guidance,	none	of	the	
income	or	expense	recognized	by	IBKC	prior	to	the	merger	
is	included	in	our	income	or	expense	for	2020.	As	a	result,	
our	2020	operating	results	consist	of	approximately	two	
quarters	of	legacy	First	Horizon	plus	approximately	two	
quarters	of	combined	First	Horizon	and	IBKC.	In	addition,	
operating	results	in	2020	were	significantly	affected	by	
merger-related	expenses	and	by	two	significant	
accounting	impacts,	described	in	Large	Accounting	
Impacts	from	IBKC	Merger	below.

In	July	2020,	we	purchased	30	branches	in	North	Carolina	
(20),	Virginia	(8),	and	Georgia	(2)	from	SunTrust	Bank	(now	
Truist	Bank).	Those	branches	are	in	markets	which	we	did	
not	serve	before	July,	or	in	which	we	did	not	have	a	
leading	market	position.	Along	with	the	branch	facilities,	
we	acquired	$0.4	billion	of	related	loans	and	assumed	
$2.2	billion	of	deposits.	

Large	Accounting	Impacts	from	IBKC	Merger

Under	applicable	accounting	guidance,	closing	the	IBKC	
merger	in	July	created	two	substantial	impacts	on	our	
operating	results	for	2020.	First,	although	we	were	
required	to	record	IBKC’s	loans	at	fair	value	on	the	closing	
date,	we	also	were	required	to	recognize,	as	a	provision	
for	credit	losses,	an	estimate	of	current	expected	credit	
losses	for	certain	acquired	loans.	A	similar	process,	with	
much	smaller	numbers,	occurred	for	the	loans	associated	
with	the	30-branch	purchase.	The	overall	incremental	
expense,	recorded	in	third	quarter	2020,	was	$147	million.	
Moreover,	we	were	required	to	record,	on	a	preliminary	
basis,	a	nontaxable	purchase	accounting	gain	from	the	
merger	of	$533	million,	driven	by	the	stock	market	decline	
in	2020	associated	with	the	COVID-19	pandemic.	The	net	
result	of	those	two	impacts	was	a	$386	million	uplift	to	
our	pretax	income	in	2020	unrelated	to	the	ordinary	
operation	of	our	businesses.

Expenses	related	to	IBKC	Merger

Closing	the	IBKC	merger,	integrating	the	business	
operations	and	systems,	and	making	the	changes	
necessary	to	achieve	intended	cost	and	other	synergies	
resulted	in	substantial	noninterest	expenses	in	2020	and	

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ITEM	1.	BUSINESS

Table	of	Contents

in	2021.	Additional	significant	expenses	related	to	
integration	and	optimization	will	be	incurred	in	2022.

Low	Credit	Loss	Rates	through	2019

During	2017-2019,	our	provision	for	credit	losses	was	
unusually	low,	though	in	2019	it	began	to	normalize.	
When	provision	is	low,	differences	from	year	to	year	can	
be	idiosyncratic,	driven	by	just	a	few	clients.

CECL	Accounting	and	COVID-19

Starting	in	2020,	accounting	guidance	changed,	requiring	
us	to	recognize	“current	expected	credit	loss”	on	all	loans.	
The	new	guidance	had	the	effect	of	accelerating,	
compared	to	prior	guidance,	the	recognition	of	provision	
expense	at	times	when	general	economic	conditions	
deteriorate	in	a	rapid	manner.	Starting	in	March	2020,	
government	and	public	reaction	to	the	COVID-19	
pandemic	caused	substantial	and	rapid,	and	previously	
unexpected,	business	disruption	and	economic	
deterioration.	Those	events	substantially	changed	our	
expectations	for	future	credit	loss	and,	accordingly,	our	
provision	was	significantly	elevated	in	2020.	

In	2021,	we	recognized	net	provision	credit	(negative	
expense)	in	the	year	overall,	as	a	portion	of	credit	loss	
accrued	in	2020	was	effectively	reversed	and	underlying	
credit	loss	trends	remained	modest	in	most	portfolios.	

Fixed	Income	Volatility

In	2017	and	2018,	market	conditions	were	quite	subdued	
for	our	fixed	income	business.	Starting	in	2019,	however,	
increased	market	volatility	and	the	downward	direction	of	
interest	rates	resulted	in	much	higher	trading	volume	and	
noninterest	income	in	that	business.	In	2021,	performance	
in	fixed	income	started	to	moderate	as	market	conditions	
started	to	change	again,	and	we	expect	moderation	to	
continue	into	2022.	See	the	Fixed	Income	discussion	under	
Cyclicality	within	the	Other	Business	Information	section	of		
this	Item,	which	begins	on	page	18,	for	additional	
information.

Sale	of	Visa	Class	B	Stock	in	2018

In	2018,	we	sold	our	remaining	legacy	stock	holdings	of	
Visa	for	a	large	gain,	significantly	increasing	noninterest	
income	that	year.

Capital	Bank	Merger	in	2017

Many	year-end	balance	sheet	figures	(loans,	deposits,	
etc.)	increased	substantially	in	2017	due	to	the	Capital	
Bank	transaction.	Full-year	operating	results	were	less	
noticeably	impacted	until	2018,	because	the	Capital	Bank	
transaction	closed	late	in	2017.	

Tax	Reform	in	2017

Corporate	tax	reform	in	December	2017	resulted	in	
significant	negative	adjustments	to	net	deferred	tax	asset	

balance,	driving	a	large	net	loss	in	fourth	quarter	that	
year.	Financial	results	after	2017,	in	contrast,	benefited	
significantly	from	lower	tax	rates	compared	to	earlier	
years.

Monetary	Policy	Shifts

Although	interest	rates	during	each	of	these	years	were	
quite	low	by	historical	standards,	short-term	rates	were	
raised	in	2017	and	2018.	Short-term	rates	were	reduced	in	
2019	and	again	in	2020,	the	latter	in	response	to	the	
pandemic.	An	asset-buying	program	by	the	Federal	
Reserve	put	downward	pressure	on	long-term	interest	
rates	as	well,	especially	in	2020	and	2021.	These	changes	
impacted	our	net	interest	margin,	raising	and	lowering	it	
over	this	period.	Net	interest	margin	is	a	measure	of	the	
profit	we	make	on	loans	and	other	earning	assets	in	
relation	to	our	cost	of	deposits	and	other	funding	sources.	
Because	funding	costs	cannot	realistically	fall	below	zero,	
the	very	low	rate	environment	during	2020-21	resulted	in	
historically	low	net	interest	margin	levels	for	us.

During	much	of	2021,	the	Federal	Reserve	kept	short-term	
rates	low	and	maintained	an	asset-buying	program	
intended	to	put	downward	pressure	on	long-term	rates.	
Late	in	2021,	and	continuing	into	2022,	the	Federal	
Reserve	has	signaled	that	its	asset-buying	program	will	
cease,	that	it	expects	to	start	raising	short-term	rates	in	
reaction	to	price	inflation	experienced	in	the	U.S.	during	
much	of	2021,	and	that	it	expects	to	reduce	its	asset	
holdings	once	buying	has	stopped.

Additional	information	concerning	monetary	policy	and	
changes	to	it	appears:	within	the	Effect	of	Governmental	
Policies	and	Proposals	section	of	Item	1	beginning	on	page	
29;	under	the	caption	Risks	Associated	with	Monetary	
Events	beginning	on	page	38	within	Item	1A;	and	under	
the	caption	Federal	Reserve	Policy	in	Transition	within	the	
Market	Uncertainties	and	Prospective	Trends	section	of	
2021	MD&A	(Item	7),	which	begins	on	page	99.

Mortgage-Related	Businesses

We	lend	to	mortgage	lending	companies,	we	originate	
mortgage	loans,	and	we	provide	title	and	related	services	
that	depend	significantly	on	new	and	refinanced	home	
mortgage	activity.	Lending	to	mortgage	companies	has	
been	a	significant	business	for	us	in	all	five	years	shown	in	
Table	1.7,	while	the	latter	two	businesses	were	
insignificant	for	us	until	our	merger	with	IBKC	in	2020.	

All	three	mortgage-related	businesses	benefited	
substantially	from	the	recent	low	interest	rate	
environment.	As	discussed	above,	we	expect	mortgage	
rates	to	rise	in	2022,	which	should	moderate	revenues	and	
income	in	all	three	businesses	compared	to	2021.

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Table	of	Contents

Significant Trends Past Five Years

ITEM	1.	BUSINESS

Noteworthy	trends	during	these	five	years	included:

• The	large	deposit	upticks	in	2017	and	2020	were	

• Growth	in	net	interest	income	was	significant	through	

2018,	driven	by	net	loan	growth,	interest	rate	
increases,	and	(in	2018)	the	Capital	Bank	merger.	
Growth	flattened	in	2019	as	net	loan	growth,	
especially	in	mortgage	warehouse	lending,	was	offset	
by	net	interest	margin	declines.	Margin	declines	
continued	in	2020	and	2021,	though	loan	balances	
increased	substantially	with	the	IBERIABANK	merger.

• In	2017,	an	overall	downward	trend	in	noninterest	
income	was	due	mainly	to	lower	fixed	income	
revenues,	driven	by	challenging	market	conditions.	
The	large	increase	in	2018	was	mainly	due	to	the	Visa	
stock	sale,	along	with	an	uptick	following	the	Capital	
Bank	merger.	The	2017	downward	trend	reversed	in	
2019-21	as	interest	rates	declined,	market	volatility	
increased,	and	fixed	income	revenues	improved	
markedly.	Also,	2020	and	2021	enjoyed	a	substantial	
increase	in	noninterest	income	following	the	
IBERIABANK	merger,	especially	in	relation	to	
consumer	mortgage	originations	and	related	services.

Exited Businesses

Over	the	past	five	years,	we	have	focused	primarily	on	
regional	banking	and	specialty	banking	products	and	
services.	We	have	partially	or	fully	exited	some	smaller	
businesses	during	those	years.	Exited	businesses	are	

driven	substantially	by	the	Capital	Bank,	IBERIABANK,	
and	30-branch	transactions.	Also	in	2020	and	2021,	
the	federal	Paycheck	Protection	Program	(“PPP”)	
contributed	to	deposit	growth	as	proceeds	from	PPP	
loans	boosted	average	deposit	account	balances.	
Organic	growth	in	deposits	from	core	banking	clients	
grew	throughout	this	period,	even	when	interest	
rates	were	extremely	low.	That	core	growth	is	masked	
in	some	years	by	our	deliberate	reductions	in	market-
indexed	deposits,	which	tend	to	be	higher	rate,	and	in	
other	years	by	those	large	transactions.

• Throughout	2020,	and	to	a	lesser	extent	in	2021,	
economic	and	business	disruption	related	to	the	
COVID-19	pandemic	created	substantial	challenges	
for	our	clients	and	for	our	company.	The	disruptions	
in	late	2021	from	yet	another	new	variant	of	the	virus	
have	continued	in	early	2022.	

managed	in	our	corporate	segment	currently,	and	were	
managed	in	our	non-strategic	segment	before	2020.		

2022 Merger Agreement with Toronto-Dominion Bank

On	February	27,	2022,	FHN	entered	into	an	Agreement	
and	Plan	of	Merger	(the	“TD	Merger	Agreement”)	with	
The	Toronto-Dominion	Bank,	a	Canadian	chartered	bank	
(“TD”),	TD	Bank	US	Holding	Company,	a	Delaware	
corporation	and	indirect,	wholly	owned	subsidiary	of	TD	
(“TD-US”),	and	Falcon	Holdings	Acquisition	Co.,	a	
Delaware	corporation	and	wholly	owned	subsidiary	of	TD-
US	(“Merger	Sub”).

Pursuant	to	the	TD	Merger	Agreement,	FHN	and	Merger	
Sub	will	merge	(the	“First	Holding	Company	Merger”),	
with	FHN	continuing	as	the	surviving	entity	in	the	merger.		
Following	the	First	Holding	Company	Merger,	at	the	
election	of	TD,	FHN	and	TD-US	will	merge	(the	“Second	
Holding	Company	Merger”	and,	together	with	the	First	
Holding	Company	Merger,	the	“Holding	Company	
Mergers”),	with	TD-US	continuing	as	the	surviving	entity	in	
the	merger.	

Upon	the	terms	and	subject	to	the	conditions	set	forth	in	
the	TD	Merger	Agreement,	each	share	of	FHN	common	
stock,	par	value	$0.625	per	share,	(“Company	Common	
Stock”),	issued	and	outstanding	immediately	prior	to	the	
effective	time	of	the	First	Holding	Company	Merger	(the	

“First	Effective	Time”)	will	be	converted	into	the	right	to	
receive	$25.00	(USD)	per	share	in	cash,	without	interest.		
If	the	transaction	does	not	close	on	or	before	November	
27,	2022,	shareholders	will	receive	an	additional	$0.65	per	
share	of	Company	Common	Stock	on	an	annualized	basis	
(or	approximately	5.4	cents	per	month)	for	the	period	
from	November	27,	2022	through	the	day	immediately	
prior	to	the	closing.	Each	outstanding	share	of	FHN’s	
preferred	stock,	series	B,	C,	D,	E	and	F,	will	remain	issued	
outstanding	in	connection	with	the	First	Holding	Company	
Merger.	If	TD	elects	to	effect	the	Second	Holding	Company	
Merger,	at	the	effective	time	of	the	Second	Holding	
Company	Merger,	each	outstanding	share	of	FHN’s	
preferred	stock	will	be	converted	into	a	share	of	a	newly	
created,	corresponding	series	of	TD-US	having	terms	as	
described	in	the	Merger	Agreement.

Following	the	completion	of	the	First	Holding	Company	
Merger,	at	such	time	as	determined	by	TD,	First	Horizon	
Bank	and	TD	Bank,	N.A.,	a	national	banking	association	
(“TDBNA”)	will	merge,	with	TDBNA	surviving	as	a	
subsidiary	of	TD-US	(the	“Bank	Merger”	and	together	with	
the	Holding	Company	Mergers,	the	“Proposed	TD	
Merger”).

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ITEM	1.	BUSINESS

Table	of	Contents

In	connection	with	the	execution	of	the	TD	Merger	
Agreement,	TD	has	agreed	to	purchase	from	FHN	shares	
of	non-voting	Perpetual	Convertible	Preferred	Stock,	
Series	G,	a	new	series	of	preferred	stock	of	FHN	(the	
“Series	G	Convertible	Preferred	Stock”)	in	a	private	
placement	transaction	having	an	aggregate	liquidation	
preference	and	purchase	price	of	approximately	$493.5	
million,	pursuant	to	a	securities	purchase	agreement	
between	FHN	and	TD	entered	into	concurrently	with	the	
execution	and	delivery	of	the	TD	Merger	Agreement.	The	
Series	G	Convertible	Preferred	Stock	is	convertible	into	up	
to	4.9%	of	the	outstanding	shares	of	Company	Common	

Competition

In	all	aspects	of	the	businesses	in	which	we	engage,	we	
face	substantial	competition	from	banks	doing	business	in	
our	markets	as	well	as	from	savings	and	loan	associations,	
credit	unions,	other	financial	institutions,	consumer	
finance	companies,	trust	companies,	investment	

Banking Competition

Our	regional	banking	business	primarily	competes	in	those	
areas	within	the	southern	U.S.	where	we	have	banking	
center	locations,	summarized	in	Table	1.2.	However,	
competition	in	our	industry	is	trending	away	from	the	
traditional	geographic	footprint	model.	That	trend	is	
happening	throughout	the	industry,	but	the	rate	of	change	
is	highly	uneven	among	different	types	of	clients,	
products,	and	services.	In	our	company,	that	trend	is	most	
evident	in	our	specialty	banking	segment.

Our	regional	banking	business	serves	both	consumer	and	
commercial	clients.	The	consumer	businesses	remain	
strongly	linked	to	our	physical	banking	center	locations,	
even	as	our	delivery	of	financial	services	to	consumers	is	
increasingly	focused	on	popular	non-physical	delivery	
methods,	such	as	online	and	mobile	banking.	Online	and	
mobile	banking	have	contributed	to	a	decline	in	banking	
center	usage,	but	not	(so	far)	an	erosion	of	the	link	
between	banking	center	versus	consumer	client	location.	
Increasingly,	however,	consumers	are	able	to	manage,	
through	a	single	institution,	their	financial	accounts	at	
multiple	institutions.	Cross-institutional	management	
features	may	contribute	to	a	de-linking	of	consumers	to	
physical	banking	center	networks.	

Our	commercial	businesses,	especially	in	our	specialty	
banking	segment,	also	have	a	geographic	linkage,	but	it	is	
weaker.	Some	areas	of	specialty	lending,	such	as	franchise	
finance,	mortgage	warehouse	lending,	asset-based	
lending,	and	certain	other	specialty	businesses	(see	Fixed	
Income	Competition	below)	are	multi-regional	or	national	
in	scope	rather	than	being	heavily	centered	on	banking	
center	locations.

Stock	in	certain	circumstances,	including	the	closing	of	the	
Proposed	TD	Merger.	

Additional	information	regarding	the	Proposed	TD	Merger,	
the	TD	Merger	Agreement,	and	the	issuance	of	Series	G	
Convertible	Preferred	Stock	will	be	included	under	Item	
1.01	“Entry	into	a	Material	Definitive	Agreement”,	Item	
3.02	“Unregistered	Sales	of	Equity	Securities”,	Item	5.03	
“Amendments	to	Articles	of	Incorporation	or	Bylaws;	
Change	in	Fiscal	Year”,	and	Item	8.01	“Other	Events”	in	a	
Current	Report	on	Form	8-K	to	be	filed	by	FHN	after	this	
report	on	Form	10-K	is	filed.

counseling	firms,	money	market	and	other	mutual	funds,	
insurance	companies	and	agencies,	securities	firms,	
mortgage	banking	companies,	hedge	funds,	and	other	
firms	offering	financial	products	or	services.	

Citizens	Bank	&	Trust	Company	(dba	First	Citizens	Bank),	
Synovus	Bank,	Truist	Bank,	Regions	Bank,	JPMorgan	Chase	
Bank	National	Association,	PNC	Bank	National	Association,	
BankUnited,	Hancock	Whitney	Bank,	and	Pinnacle	Bank,	
among	many	others	including	many	community	banks	and	
credit	unions.	

A	number	of	recent	technologies	created	or	operated	by	
non-banks	have	been	integrated	into	the	financial	systems	
used	by	traditional	banks,	such	as	the	evolution	of	ATM	
cards	into	debit/credit	cards	and	the	evolution	of	debit/
credit	cards	into	smart	phones.	These	sorts	of	
incrementally	evolutionary	technologies	often	have	
expanded	the	market	for	banking	services	overall	while	
siphoning	a	portion	of	the	revenues	from	those	services	
away	from	banks.	Prior	methods	of	delivering	those	
services	were	disrupted,	but	often	at	a	pace	which	all	but	
the	weakest	banks	could	accommodate.	

Recently,	some	evolutionary	pressures	have	arisen	which	
may	prove	to	be	less	incremental	and	more	disruptive.	For	
example,	in	financial	planning	and	wealth	management,	
companies	that	are	not	traditional	banks,	including	both	
long-established	firms	(such	as	Vanguard)	and	new	ones	
(such	as	Betterment),	have	developed	highly-interactive	
systems	and	applications.	These	services	compete	directly	
with	traditional	banks	in	offering	personal	financial	advice.	
The	low-cost,	high-speed	nature	of	these	“robo-advisor”	
services	can	be	especially	attractive	to	younger,	less-
affluent	clients	and	potential	clients.	We	and	other	
traditional	banks	offer	similar	services,	but	doing	so	risks	
cannibalizing	traditional	business	models	for	these	
services.	

Key	traditional	competitors	in	many	of	our	markets	
include	Wells	Fargo	Bank	N.A.,	Bank	of	America	N.A.,	First-

In	recent	years,	certain	financial	companies	or	their	
affiliates	that	traditionally	were	not	banks	have	been	able	

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ITEM	1.	BUSINESS

Table	of	Contents

to	compete	more	directly	with	the	Bank	for	deposits	and	
other	traditional	banking	services	and	products.	Increased	
fluidity	across	traditional	boundaries	is	likely	to	continue.	
Non-traditional	companies	competing	with	us	for	
traditional	banking	products	and	services	include	
investment	banks,	brokerage	firms,	insurance	company	
affiliates,	peer-to-peer	lending	arrangers,	non-bank	
deposit	acceptors,	companies	offering	payment	

Fixed Income Competition

Our	fixed	income	business,	which	is	part	of	our	specialty	
banking	segment,	serves	institutional	clients,	broadly	
segregated	into	depositories	(including	banks,	thrifts,	and	
credit	unions)	and	non-depositories	(including	money	
managers,	insurance	companies,	governmental	units	and	
agencies,	public	funds,	pension	funds,	and	hedge	funds).	

Additional Information About Competition

For	additional	information	on	the	competitive	position	of	
FHN	and	the	Bank,	refer	to	the	General	subsection	above	
within	this	Item	1.	Also,	refer	to	the	subsections	entitled	
Supervision	and	Regulation	and	Effect	of	Governmental	
Policies,	both	of	which	are	relevant	to	an	analysis	of	our	

Human Resources Management 

Firstpower Culture

Our	principal	business	is	providing	financial	services	to	our	
clients.	Although	many	financial	services	can	be	delivered	
through	technology	today,	we	believe	that	our	clients’	
experiences	with	our	associates	is	a	critical	way	we	
differentiate	from	our	competitors.	Specifically,	we	ask	
our	associates	to	take	advantage	of	every	opportunity	to	
anticipate	client	needs	and	exceed	client	expectations.	

For	this	“differentiated	experience”	strategy	to	succeed,	
we	must	build	and	nurture	a	diverse	and	inclusive	
workplace	culture	that	strives	to	attract,	hire,	and	retain	
the	best	people	available	by	compensating	and,	just	as	
importantly,	treating	people	fairly;	ensure	that	associates	
have	opportunities	for	professional	growth	and	
advancement	within	the	company;	support	associates	
with	appropriate	workplace	resources	and	training;	
promote	constructive	collegiality	and	a	sense	of	workplace	
community;	encourage	innovation	and	the	development	
of	better	ways	to	address	business	challenges;	publicly	
recognize	within	the	company	associate	achievements,	
both	great	and	small;	and	promote	behaviors	that	provide	
clients	with	best-in-class	service.	At	First	Horizon,	we	call	
that	culture	“Firstpower.”

We	have	evolved	Firstpower	as	a	part	of	our	MOE	to	
incorporate	aspects	of	both	organizations—expanded	
expertise,	resources	and	geographic	footprint—into	the	
culture	of	our	company.	We	have	developed	the	following	

facilitation	services	(such	as	PayPal	and	pre-paid	debit	
card	issuers),	and	extremely	short-term	consumer	loan	
companies.	An	example	of	a	non-traditional	company	
offering	a	broad	range	of	financial	services	is	SoFi,	an	
online/mobile	company	in	operation	for	about	a	decade,	
that	recently	was	approved	in	the	U.S.	to	become	a	bank.	

Both	client	groups	are	widely	dispersed	geographically,	
predominantly	within	the	U.S.	We	have	many	competitors	
within	both	groups,	including	major	U.S.	and	international	
securities	firms	as	well	as	numerous	regional	and	local	
firms.

competitors.	Due	to	the	intense	competition	in	the	
financial	services	industry	we	can	make	no	representation	
that	our	competitive	position	has	or	will	remain	constant,	
nor	can	we	predict	how	it	may	change	in	the	future.

Purpose,	Promise	and	Principles	to	guide	our	associates	on	
our	core	values	and	philosophies.

Our	Purpose:	First	Horizon	is	a	relationship-driven	leading	
provider	of	financial	solutions.

Our	Promise:	To	strengthen	the	lives	of	our	associates,	
clients	and	communities.

Our	Principles:

• Great	Place	To	Work	–	offer	a	collaborative	and	
inclusive	workplace	that	promotes	associate	
development,	performance	and	success

• Build	Strong	Relationships	–	exceed	clients’	

expectations	by	understanding	their	unique	needs

• Deliver	Results	–	consistently	deliver	shareholder	

value

• Give	Back	–	invest	in	strategic	partnerships	to	build	

strong	communities

• Fortitude	–	lead	with	integrity,	accountability,	agility,	

resilience	and	compassion

We	use	many	tools	and	resources—programs,	events,	
promotions,	communication	channels—to	nurture	and	
enhance	our	Firstpower	culture.	We	focus	on	offering	a	
variety	of	opportunities	that	promote	mentoring,	
wellness,	internships,	diversity,	inclusion,	volunteering,	
informal	shout-outs	and	formal	recognitions,	career	

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ITEM	1.	BUSINESS

Table	of	Contents

management	and	continuing	education,	resource	groups,	
and	parental	and	care-giver	support.	

We	believe	that	Firstpower	is	responsible	for	awards	and	
recognitions	we	have	received.	Our	recent	recognitions	
have	included:	Forbes’	America’s	Best	Large	Employers;	
Forbes’	World’s	Best	Banks;	Fortune’s	Best	Workplaces	in	
Finance	and	Insurance;	National	Association	for	Female	
Executives	–	Top	50	Companies	for	Executive	Women;	
Dave	Thomas’	Adoption-Friendly	Workplaces;	Diversity	
Best	Practices	Inclusion;	and	Bloomberg	2019	Gender-
Equality	Index.	

In	addition	to	our	Firstpower	culture,	we	have	developed	
five	strategic	pillars	for	our	Diversity,	Equity	and	Inclusion	

Year-End Statistical Information

At	December	31,	2021*:	

• First	Horizon	had	7,867	associates,	or	7,676	full-time-
equivalent	associates,	not	including	contract	labor	for	
certain	services:

◦ 69%	white,	18%	African	American,	9%	Hispanic,	2%	

Asian,	and	2%	two	or	more	races	or	ethnicities

◦ 63%	female	and	37%	male

• Of	those,	First	Horizon	had	1,215	corporate	managers:

◦ 79%	white,	12%	African	American,	6%	Hispanic,	2%	

Asian,	and	1%	two	or	more	races	or	ethnicities

Other Business Information

Strategic Transactions

An	element	of	our	business	strategy	is	to	consider	
acquisitions	and	divestitures	that	would	enhance	long-
term	shareholder	value.	Significant	acquisitions	and	
divestitures	which	closed	during	the	past	three	years	are	
described	in	Note	2	to	our	2021	Financial	Statements	
(Item	8),	beginning	on	page	134	of	this	report.	

The	most	significant	transactions	in	the	past	five	years	are	
our	merger	of	equals	with	IBKC	in	2020	and	our	merger	
with	Capital	Bank	Financial	Corp.	in	2017.	IBKC’s	assets	
comprised	roughly	three-sevenths	of	our	combined	assets	
immediately	after	closing	in	July	2020.	Capital	Bank’s	

Subsidiaries

FHN’s	consolidated	operating	subsidiaries	at	
December	31,	2021	are	listed	in	Exhibit	21.	Technical	and	
regulatory	details	follow:	

• The	Bank	is	supervised	and	regulated	as	described	in	

Supervision	and	Regulation	in	this	Item	below.

• The	Bank	is	a	government	securities	dealer.	The	FHN	
Financial	division	of	the	Bank	is	registered	with	the	
SEC	as	a	municipal	securities	dealer	and	the	FHN	

program	that	builds	upon	our	track	record	of	success,	
helps	to	ensure	adoption	throughout	our	organization,	
and	defines	a	path	for	sustainable	progress.		We	enable	
our	DEI	strategy	through:

• Ensuring	representation	of	diverse	talent

• Strengthening	leadership	capabilities	and	

accountability	

• Fostering	inclusion	and	equality	through	fairness	and	

transparency

• Better	serving	diverse	markets	and	clients

• Investing	in	the	well-being	of	communities

◦ 54%	female	and	46%	male	

• Of	the	managers,	First	Horizon	had	the	CEO	and	9	
members	of	the	CEO's	Executive	Management	
Committee:

◦ 80%	white,	10%	African	American,	0%	Hispanic	or	
Asian,	and	10%	two	or	more	races	or	ethnicities

◦ 50%	female	and	50%	male	

__________
*	 Data	compiled	from	information	provided	by	associates.	Percentages	

may	not	add	to	100%	due	to	rounding.

assets	comprised	roughly	one-fourth	of	our	combined	
assets	immediately	after	closing	in	November	2017.	We	
completed	systems	integration	for	the	Capital	Bank	
transaction	in	2018,	and	we	completed	systems	
integration	with	IBKC	in	February	2022.

Other	significant	transactions	include	our	purchase	of	30	
banking	centers	in	July	2020,	with	over	$2	billion	of	
associated	deposits,	and	our	acquisition	of	Coastal	
Securities,	Inc.	in	2017,	a	leader	in	trading	and	securitizing	
SBA	loans.

Financial	Municipal	Advisors	division	of	the	Bank	is	
registered	with	the	SEC	as	a	municipal	adviser.	

• Martin	and	Company,	Inc.,	First	Horizon	Advisors,	Inc.,	

and	FHN	Financial	Main	Street	Advisors,	LLC	are	
registered	with	the	SEC	as	investment	advisers.

• First	Horizon	Advisors,	Inc.	and	FHN	Financial	

Securities	Corp.	are	registered	as	broker-dealers	with	
the	SEC	and	all	states	where	they	conduct	business	
for	which	registration	is	required.	

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ITEM	1.	BUSINESS

Table	of	Contents

• First	Horizon	Insurance	Services,	Inc.,	FHIS,	Inc.,	First	

Horizon	Insurance	Agency,	Inc.,	Lenders	Title	
Company,	United	Title	&	Abstract	L.L.C.,	and	United	
Title	of	Louisiana,	Inc.	are	licensed	as	insurance	
agencies	in	all	states	where	they	do	business	for	
which	licensing	is	required.	First	Horizon	Insurance	
Agency,	Inc.	and	United	Title	&	Abstract	L.L.C.	are	
inactive.

• First	Horizon	Advisors,	Inc.	is	licensed	as	an	insurance	
agency	in	the	states	where	it	does	business	for	which	
licensing	is	required	for	the	sale	of	annuity	products.	

Client Concentration

• Our	financial	subsidiaries	under	the	Gramm-Leach-
Bliley	Act	are:	FHIS,	Inc.;	FHN	Financial	Securities	
Corp.;	First	Horizon	Advisors,	Inc.;	First	Horizon	
Insurance	Agency,	Inc.;	and	First	Horizon	Insurance	
Services,	Inc.	

Neither	we	nor	any	of	our	significant	subsidiaries	is	dependent	upon	a	single	client	or	very	few	clients.

Calendar-Year Seasonality

We	do	not	experience	material	seasonality.	We	do	
experience	seasonal	variation	in	certain	revenues,	
expenses,	and	credit	trends.	Historically,	these	variations	
have	somewhat	increased	certain	expenses	and	
diminished	certain	revenues	for	the	regional	and	specialty	
banking	segments,	principally	in	the	first	quarter	each	
year.	In	addition,	we	experience	seasonal	variation	in	
certain	asset	and	liability	balances,	principally	in	the	

Cyclicality

Banking

Financial	services	facilitate	commercial	and	consumer	
economic	activities	in	critical	ways.	In	many	key	respects,	
modern	financial	services	make	modern	types	and	
volumes	of	economic	activity	possible.	Put	simply,	we	do	
well	when	our	clients	do	well,	and	vice-versa.	As	a	result,	
our	banking	business	is	broadly	and	strongly	dependent	
on	the	size	and	strength	of	the	U.S.	economy.	

Generally,	when	the	U.S.	economy	is	in	an	expansionary	
phase	of	the	business	cycle,	our	loan	balances	rise,	income	
from	lending	tends	to	rise	(assuming	static	interest	rates	
and	margins),	credit	losses	tend	to	fall,	and	fee	income	
tends	to	increase.	In	a	contracting	phase,	those	patterns	
tend	to	reverse.	The	impact	of	those	factors	on	our	
operating	results	can	be	substantial,	especially	if	they	
consistently	move	up	or	down	at	the	same	time.

Our	traditional	banking	businesses	are	crucially	dependent	
on	the	level	of	interest	rates,	whether	federal	monetary	
policy	is	easing	or	tightening,	and	on	the	shape	of	the	
interest	rate	yield	curve.	These	factors	also	are	cyclical,	
and	are	related	in	complex	ways	with	the	business	cycle	
mentioned	above.	

These	factors,	and	their	impacts	on	us,	often	are	mixed	
rather	than	consistently	positive	or	negative.	For	example:	
low	interest	rates	reduce	the	interest	income	we	earn,	
reduce	our	costs	of	funding,	tend	to	stimulate	economic	

fourth	quarter	(consumer	mortgages,	related	title	
services,	commercial	lending	related	to	consumer	
mortgages,	certain	trading	balances,	and	certain	
associate-related	reserves)	and	first	quarter	(consumer	
mortgages,	related	title	services,	and	commercial	lending	
related	to	consumer	mortgages).

activity	and	loan	growth,	and,	through	lower	debt	service,	
tend	to	ease	financial	pressure	on	clients,	reducing	default	
risk.	If	the	yield	curve	remains	relatively	steep,	with	long-
term	interest	rates	noticeably	higher	than	short	rates,	our	
net	interest	margin	will	tend	not	to	be	significantly	
compressed	by	the	lower	rate	environment,	since	lower	
short	rates	will	keep	our	deposit	costs	down	while	higher	
long	rates	will	support	the	rates	we	can	charge	on	lending.	
But	if	rates	fall	low	enough	(as	they	have	in	recent	years),	
the	yield	curve	will	flatten	and	our	margins	will	suffer.	
Moreover,	the	Federal	Reserve	tends	to	lower	rates	in	
response	to,	or	to	avoid,	a	weakening	economy.	Economic	
weakness	tends	to	diminish	client	borrowing	and	other	
activities	which	benefit	our	performance.

Further	information	on	these	topics	is	presented:	within	
Item	1A	(which	begins	on	page	31),	in	Risk	from	Economic	
Downturns	and	Changes,	Risks	Associated	with	Monetary	
Events,	Liquidity	and	Funding	Risks,	and	Interest	Rate	and	
Yield	Curve	Risks;	and,	within	2021	MD&A	(Item	7),	in	
Executive	Overview	(page	61),	Interest	Rate	Risk	
Management	(page	93),	and	Market	Uncertainties	and	
Prospective	Trends	(page	99).	

Fixed	Income

Our	fixed	income	and	capital	markets	business,	reported	
as	part	of	our	specialty	banking	segment,	is	significantly	
affected	by	interest	rate	cycles	which,	in	turn,	are	affected	
by	general	economic	and	business	cycles.	

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Weaker

Average

Stronger

Mortgage	Origination	and	Related	Services

ITEM	1.	BUSINESS

Table	of	Contents

In	broad	terms,	the	typical	impact	of	Federal	Reserve	
interest	and	monetary	policy	on	our	fixed	income	business	
is	summarized	in	Table	1.8.

Table	1.8

Typical	Impact	of	Fed	Policy	on	
Fixed	Income	Performance

Federal	Reserve	Policy	Phase
Easing
Neutral

Tightening

Fixed	Income	
Performance	Tends	to	
be

“Tightening”	can	include	actions	by	the	Federal	Reserve	to	
raise	short-term	interest	rates,	raise	long-term	rates,	
tighten	credit,	shrink	the	money	supply,	and	decelerate	
economic	activity.	“Easing”	can	include	actions	by	the	
Federal	Reserve	to	lower	short-term	interest	rates,	lower	
long-term	rates,	loosen	credit,	expand	the	money	supply,	
and	accelerate	economic	activity.	Expectations	of	policy	
actions	can	have	impacts	similar	to	the	actions	
themselves.

In	terms	of	tightening	vs.	easing,	the	Federal	Reserve	
policy	phase	sometimes	is	clearly	known,	but	sometimes	is	
not.	Although	Federal	Reserve	actions	at	a	given	time	can	
consistently	support	one	phase,	often	they	are	a	mix.	For	
example,	The	Federal	Reserve	may	want	to	flatten	the	
yield	curve	by	raising	short-term	rates	while	lowering	
long-term	rates,	or	steepen	the	curve	by	taking	the	
opposite	actions.	Also,	major	exogenous	factors,	such	as	
the	COVID-19	pandemic,	can	significantly	impact	the	
capital	markets	and	the	performance	of	our	fixed	income	
business.	In	broad	terms,	these	relationships	are	
summarized	in	Table	1.9.	

Table	1.9

Key	Drivers	of	
Fixed	Income	Performance

Driver

If	Driver	Is:

FI	Revenues	Tend	to	Be:

Interest rates

Market	
volatility

Yield curve

Credit	spreads

Economy 
outlook

Rising

Falling
Low

Moderate

Flatter

Steeper
Narrower

Wider

Positive

Negative

Lower

Higher
Lower

Higher

Lower

Higher
Lower

Higher

Lower

Higher

In	many	circumstances	these	drivers	deliver	mixed	
impacts	on	fixed	income	performance,	with	some	pushing	
higher	while	others	push	lower,	or	with	some	drivers	
pushing	weakly	while	others	are	stronger.	If	most	or	all	
drivers	strongly	push	in	the	same	direction	at	the	same	
time,	fixed	income	performance	usually	is	strongly	
impacted.	Revenue	levels	in	a	strongly	“higher”	year	can	
be	more	than	double	what	they	are	in	a	strongly	“lower”	
year.	As	a	result,	fixed	income	performance	can	be	highly	
variable	from	year	to	year.	

The	strength	of	consumer	mortgage	lending	activity	in	the	
U.S.	impacts	three	businesses	of	ours:	mortgage	
origination	and	related	services,	title	services,	and	
commercial	lending	to	other	mortgage	lenders.	

Mortgage	lending	activity	is	strongly	linked	to	interest	rate	
cycles.	Activity	tends	to	be	inversely	related	to	prevailing	
mortgage	rates:	when	rates	are	high,	home-buying	and	
refinancing	decrease,	and	when	rates	are	low,	home-
buying	and	refinancing	increase.	Moreover,	expectations	
about	near-term	future	mortgage	rates	can	accelerate	or	
delay	those	impacts,	as	borrowers	rush	to	avoid	future	
rate	increases	or	wait	for	future	rate	decreases.

Market	Outlook

The	single	most	important	market	factor	in	2022	for	FHN	
likely	will	be	when,	and	to	what	extent,	short-term	and	
long-term	interest	rates	rise	from	the	very	low	levels	seen	
in	2020	and	2021.	A	key	corollary	will	be	how	rate	changes	
affect	the	shape	of	the	yield	curve.	Early	in	2022,	when	
this	report	was	prepared	and	filed,	long-term	rates	in	the	
markets	have	risen	modestly	in	reaction	to,	and	perhaps	in	
anticipation	of,	Federal	Reserve	actions.	FHN	believes	it	is	
likely	that	the	Federal	Reserve	will	act	to	cause	long	and	
short	rates	to	rise	during	the	year,	though	FHN	cannot	
predict	the	timing	or	degree	of	effectiveness	of	those	
actions.

Additional	information	concerning	market	uncertainties	
and	trends	appears	in	Market	Uncertainties	and	
Prospective	Trends	within	2021	MD&A	(Item	7)	beginning	
on	page	99,	especially	under	the	captions	Federal	Reserve	
Policy	in	Transition	and	COVID-19	Pandemic.	

Other Business Information Associated with this Report

For	additional	information	concerning	our	business,	refer	to	2021	MD&A	(Item	7).	

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Table	of	Contents

Business Information External to this Report

ITEM	1.	BUSINESS

Our	current	primary	internet	address	is	
www.firsthorizon.com.	A	link	to	the	Investor	Relations	
section	of	our	internet	website	appears	near	the	bottom	
of	the	home	page	of	our	website.	Within	the	Investor	
Relations	homepage	there	is	a	"Learn	More"	link	
associated	with	"SEC	Filings."	Clicking	that	link	makes	
available	to	the	public,	free	of	charge,	our	annual	reports	
on	Form	10-K,	quarterly	reports	on	Form	10-Q,	current	
reports	on	Form	8-K,	proxy	statements,	and	amendments	

Supervision and Regulation

Scope of this Section

This	section	describes	certain	of	the	material	elements	of	
the	regulatory	framework	applicable	to	bank	and	financial	
holding	companies	and	their	subsidiaries,	and	to	
companies	engaged	in	securities	and	insurance	activities.	
It	also	provides	certain	specific	information	about	us.	To	
the	extent	that	the	following	information	describes	

Overview

The	Corporation

First	Horizon	Corporation	is	a	bank	holding	company	and	
financial	holding	company	within	the	meaning	of	the	Bank	
Holding	Company	Act	of	1956,	as	amended	(the	“BHCA”),	
and	is	registered	with	the	Federal	Reserve.	We	are	subject	
to	the	regulation	and	supervision	of,	and	to	examination	
by,	the	Federal	Reserve	under	the	BHCA.	We	are	required	
to	file	with	the	Federal	Reserve	annual	reports	and	such	
additional	information	as	the	Federal	Reserve	may	require	
pursuant	to	the	BHCA.	

A	bank	holding	company	that	is	not	a	financial	holding	
company	is	limited	to	engaging	in	“banking”	and	activities	
found	by	the	Federal	Reserve	to	be	“closely	related	to	
banking.”	Eligible	bank	holding	companies	that	elect	to	
become	financial	holding	companies	may	affiliate	with	
securities	firms	and	insurance	companies	and	engage	in	a	
broader	range	of	activities	that	are	“financial	in	nature.”		
See	Financial	Activities	other	than	Banking	within	this	
Supervision	and	Regulation	discussion	below.	

The	Federal	Reserve	may	approve	an	application	by	a	bank	
holding	company	to	acquire	a	bank	located	outside	the	
acquirer’s	principal	state	of	operations	without	regard	to	
whether	the	transaction	is	prohibited	under	state	law,	
although	state	law	may	still	impose	certain	requirements.	
See	Interstate	Branching	and	Mergers	and	Community	
Reinvestment	Act	(“CRA”),	both	within	this	Supervision	
and	Regulation	discussion	below.	

The	Tennessee	Bank	Structure	Act	of	1974,	among	other	
things,	prohibits	(subject	to	certain	exceptions)	a	bank	
holding	company	from	acquiring	a	bank	for	which	the	

thereto	as	soon	as	reasonably	practicable	after	we	file	
such	material	with,	or	furnish	such	material	to,	the	
Securities	and	Exchange	Commission.	Additional	
information	regarding	materials	available	on	our	website	
is	provided	in	Item	10	of	this	report	beginning	on	page	
214.	No	information	external	to	this	report	and	its	
exhibits,	unless	specifically	noted	otherwise,	is	
incorporated	into	this	report.

statutory	and	regulatory	provisions,	it	is	qualified	in	its	
entirety	by	express	reference	to	each	of	the	particular	
statutory	and	regulatory	provisions.	A	change	in	applicable	
statutes,	regulations,	or	regulatory	policy	may	have	a	
material	effect	on	our	business.	

home	state	is	Tennessee	(a	“Tennessee	bank”)	if,	upon	
consummation,	the	company	would	directly	or	indirectly	
control	30%	or	more	of	the	total	deposits	in	insured	
depository	institutions	in	Tennessee.	As	of	June	30,	2021,	
the	FDIC	reports	that	the	Bank	held	approximately	15%	of	
such	deposits.	

The	Bank

First	Horizon	Bank,	our	most	significant	subsidiary,	is	a	
Tennessee	banking	corporation	subject	to	the	regulation	
and	supervision	of,	and	to	examination	by,	the	TDFI.	In	
addition	to	general	supervision	and	examination	powers,	
the	TDFI	has	the	power	to	approve	mergers	with	the	Bank,	
the	Bank’s	issuance	of	preferred	stock	or	capital	notes,	the	
establishment	of	banking	centers,	and	many	other	
corporate	actions.

The	Bank	has	chosen	to	be	a	member	of	the	Federal	
Reserve.		As	a	result,	the	Federal	Reserve	is	the	Bank’s	
primary	federal	regulator.	As	a	member,	the	Bank	must	
buy	and	hold	stock	in	its	district	Federal	Reserve	Bank	
equal	to	6%	of	the	Bank’s	capital	stock	and	surplus.	The	
Bank	is	paid	a	dividend	on	its	investment	at	a	rate	which	
varies	with	ten-year	U.S.	Treasury	rates,	capped	at	6%.	
The	Bank	cannot	sell	its	investment	in	Federal	Reserve	
Bank	stock,	and	the	investment	provides	the	Bank	with	no	
control	over	the	Federal	Reserve	System.

Tennessee	law	requires	the	Bank,	as	a	member	of	the	
Federal	Reserve,	to	comply	with	federal	capital	and	many	
other	regulatory	requirements	in	lieu	of,	or	sometimes	in	
addition	to,	state	requirements.	For	that	reason,	this	
Supervision	and	Regulation	section	focuses	on	federal	

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requirements	for	many	topics	related	to	the	Bank,	
mentioning	state	requirements	only	where	significant.

From	1864	until	2019,	the	Bank	was	a	national	banking	
association	subject	to	the	regulation	and	supervision	of,	
and	to	examination	by,	the	Office	of	the	Comptroller	of	
the	Currency.	In	2019,	the	Bank	converted	from	a	national	
bank	to	a	Tennessee	state	bank.	Conversion	did	not	
significantly	alter	the	scope	of	the	Bank’s	activities:	
Tennessee	law	generally	allows	a	Tennessee	state	bank	to	
take	any	action	that	a	Tennessee-based	national	bank	
could	take.

The	Bank	is	insured	by,	and	subject	to	regulation	by,	the	
FDIC	and	is	subject	to	regulation	in	certain	respects	by	the	
CFPB.	The	Bank	is	also	subject	to	various	requirements	
and	restrictions	under	federal	and	state	law,	including	
requirements	to	maintain	reserves	against	deposits,	
restrictions	on	the	types	and	amounts	of	loans	that	may	
be	made	and	the	interest	that	may	be	charged,	limitations	
on	the	types	of	investments	that	may	be	made,	activities	

Regulatory Tiers Based on Asset Size

Many	rules	dealing	with	critical	regulatory	topics	divide	
banks	into	tiers	based	largely	or	entirely	on	asset	size.	
Different	topics	have	different	cut-off	points	for	the	tiers.	
Within	each	topic,	different	rules	apply	to	the	different	
tiers.	

Cut-off	points	vary	significantly.	However,	as	a	rough	
generalization,	for	many	regulatory	topics	the	critical	cut-
off	points	are	$10	billion,	$100	billion,	and	$250	billion.	
Companies	with	less	than	$10	billion	are	less	regulated	in	
several	important	ways	than	we	are,	and	companies	with	

Large-Bank Supervision Risk Categories

Federal	regulators	have	established	four	risk-based	
categories	for	applying	enhanced	prudential	standards	
(enhanced	for	larger	banks).	Category	I	applies	to	the	
global	systemically	important	companies.	Categories	II,	III,	
and	IV	apply	(with	certain	exceptions)	to	institutions	with	
total	consolidated	assets	of	at	least	$700	billion,	$250	

Payment of Dividends

First	Horizon	Corporation	is	a	legal	entity	separate	and	
distinct	from	First	Horizon	Bank	and	other	subsidiaries.	
Our	principal	source	of	cash	flow,	including	cash	flow	to	
pay	dividends	on	our	stock	or	to	pay	principal	(including	
premium,	if	any)	and	interest	on	debt	securities,	is	
dividends	from	the	Bank.	There	are	statutory	and	
regulatory	limitations	on	the	payment	of	dividends	by	the	
Bank	to	us,	as	well	as	by	us	to	ours	shareholders.

that	may	be	engaged	in,	and	types	of	services	that	may	be	
offered.	Various	consumer	laws	and	regulations	also	affect	
the	operations	of	the	Bank.	In	addition,	several	of	the	
Bank’s	subsidiaries	are	regulated	separately,	as	discussed	
in	Subsidiaries	within	this	Item	1	under	the	Other	Business	
Information	discussion	above,	which	begins	on	page	18.

In	addition	to	the	impact	of	regulation,	commercial	banks	
are	affected	significantly	by	the	actions	of	the	Federal	
Reserve	as	it	attempts	to	control	interest	rates,	money	
supply,	and	credit	availability	in	order	to	influence	the	
economy.	Also,	the	Bank	and	certain	of	its	subsidiaries	are	
prohibited	from	engaging	in	certain	tie-in	arrangements	in	
connection	with	extensions	of	credit,	leases	or	sales	of	
property,	or	furnishing	products	or	services.

The	regulatory	framework	governing	banks	and	the	
financial	industry	is	intended	primarily	to	protect	
depositors	and	the	Federal	Deposit	Insurance	Fund,	not	to	
protect	our	Bank	or	our	security	holders.

$250	billion	or	more	are	regulated	much	more	severely	in	
many	important	ways	than	we	are.	As	a	result,	under	
current	law,	compliance	costs	and	restrictions	grow	with	
size,	they	tend	to	change	abruptly	as	a	company	crosses	to	
the	next	tier,	and	we	are	in	a	middle	tier	in	many	respects.

The	remainder	of	this	Supervision	and	Regulation	
discussion	focuses	on	current	rules	which	apply	to	FHN	
based	on	our	current	asset	size.

billion,	and	$100	billion,	respectively.	Currently,	we	and	
the	Bank	are	below	Category	IV’s	floor	and	therefore,	
generally,	we	are	not	subject	to	enhanced	prudential	
standards.	

due	in	the	usual	course	of	business	or	our	total	assets	
would	be	less	than	the	sum	of	our	total	liabilities	plus	any	
amounts	needed	to	satisfy	any	preferential	rights	if	we	
were	dissolving.	In	addition,	in	deciding	whether	or	not	to	
declare	a	dividend	of	any	particular	size,	our	Board	must	
consider	our	current	and	prospective	capital,	liquidity,	and	
other	needs,	including	the	needs	of	the	Bank	which	we	are	
obligated	to	support.	

The	Corporation

The	Bank

Under	Tennessee	corporate	law,	we	are	not	permitted	to	
pay	cash	dividends	if,	after	giving	effect	to	such	payment,	
we	would	not	be	able	to	pay	our	debts	as	they	become	

Under	Tennessee	corporate	law,	the	Bank	(like	the	
Corporation,	discussed	above)	may	not	pay	a	dividend	if	
the	Bank	would	not	be	able	to	pay	its	debts	when	due	or	if	

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the	Bank’s	assets	would	be	inadequate,	in	a	dissolution,	to	
pay	liabilities	and	preferential	rights.	Similarly,	the	Bank’s	
Board	must	consider	current	and	prospective	needs	in	
making	a	decision	to	declare	a	dividend.

In	addition,	in	order	to	pay	cash	dividends,	the	Bank	must	
obtain	the	prior	approval	of	the	Federal	Reserve	and	the	
TDFI	Commissioner	if	the	total	of	all	dividends	declared	by	
the	Bank’s	board	of	directors	in	any	calendar	year	exceeds	
the	total	of	(i)	the	Bank’s	retained	net	income	for	that	year	
plus	(ii)	the	Bank’s	retained	net	income	for	the	preceding	
two	years,	less	certain	required	capital	transfers,	as	
applicable.	Below	that	ceiling,	approval	generally	is	not	
required	(but	see	Other	Factors	Affecting	Dividends	
immediately	following	this	discussion).	Applying	the	
dividend	restrictions	imposed	under	applicable	federal	
and	state	rules,	the	Bank’s	total	amount	available	for	
dividends,	without	obtaining	regulatory	approval,	was	
$1.1	billion	at	January	1,	2022.	The	application	of	those	
restrictions	to	the	Bank	is	discussed	in	more	detail	in	the	
following	sections,	all	of	which	is	incorporated	into	this	
Item	1	by	reference:	under	the	caption	Liquidity	Risk	
Management	in	our	2021	MD&A	(Item	7)	beginning	on	
page	95	of	this	report;	and	under	the	caption	Restrictions	
on	dividends	in	Note	13—Regulatory	Capital	and	
Restrictions	of	our	2021	Financial	Statements	(Item	8),	
beginning	on	page	159.

Other	Factors	Affecting	Dividends

If,	in	the	opinion	of	the	Federal	Reserve,	we	or	the	Bank	
are	engaged	in	or	about	to	engage	in	an	unsafe	or	
unsound	practice	(which,	depending	on	the	financial	
condition	of	FHN	or	the	Bank,	could	include	the	payment	
of	dividends),	the	Federal	Reserve	may	require	us	or	the	
Bank	to	cease	and	desist	from	that	practice.	The	federal	
banking	agencies	have	indicated	that	paying	dividends	
that	deplete	a	depository	institution’s	or	holding	

Transactions with Affiliates

The	Bank’s	ability	to	lend	or	extend	credit	to	its	parent	
company	or	nonbank	subsidiaries	(including	for	purposes	
of	this	paragraph,	in	certain	situations,	subsidiaries	of	the	
Bank)	is	restricted.	The	Bank	and	its	subsidiaries	generally	
may	not	extend	credit	to	us	or	to	any	other	affiliate	in	an	
amount	which	exceeds	10%	of	the	Bank’s	capital	stock	and	
surplus	and	may	not	extend	credit	in	the	aggregate	to	us	
and	all	such	affiliates	in	an	amount	which	exceeds	20%	of	
its	capital	stock	and	surplus.	Extensions	of	credit	and	other	
transactions	between	the	Bank	and	us	or	such	other	
affiliates	must	be	on	terms	and	under	circumstances,	
including	credit	standards,	that	are	substantially	the	same	
or	at	least	as	favorable	to	the	Bank	as	those	prevailing	at	
the	time	for	comparable	transactions	with	non-affiliated	
companies.	Further,	the	type,	amount,	and	quality	of	

company’s	capital	base	to	an	inadequate	level	would	be	
an	unsafe	and	unsound	banking	practice.	

In	addition,	under	the	Federal	Deposit	Insurance	Act,	an	
FDIC-insured	depository	institution	(such	as	the	Bank)	may	
not	make	any	capital	distributions,	pay	any	management	
fees	to	its	holding	company,	or	pay	any	dividend	if	it	is	
undercapitalized	or	if	such	payment	would	cause	it	to	
become	undercapitalized.	

The	payment	of	cash	dividends	by	us	or	by	the	Bank	also	
may	be	affected	or	limited	by	other	factors,	such	as	the	
requirement	to	maintain	adequate	capital	above	
regulatory	guidelines	and	requirements	imposed	by	debt	
covenants.	For	example,	as	discussed	under	Capital	
Adequacy	within	this	Supervision	and	Regulation	
discussion	below,	our	ability	to	pay	dividends	would	be	
restricted	if	its	capital	ratios	fell	below	minimum	
regulatory	requirements	plus	a	capital	conservation	
buffer.	

The	Federal	Reserve	generally	requires	insured	banks	and	
bank	holding	companies	to	pay	dividends	only	out	of	
current	operating	earnings.	The	Federal	Reserve	has	
released	a	supervisory	letter	advising,	among	other	things,	
that	a	bank	holding	company	should	inform	the	Federal	
Reserve	and	should	eliminate,	defer,	or	significantly	
reduce	its	dividends	if	(i)	the	bank	holding	company’s	net	
income	available	to	shareholders	for	the	past	four	
quarters,	net	of	dividends	previously	paid	during	that	
period,	is	not	sufficient	to	fully	fund	the	dividends;	(ii)	the	
bank	holding	company’s	prospective	rate	of	earnings	is	
not	consistent	with	the	bank	holding	company’s	capital	
needs	and	overall	current	and	prospective	financial	
condition;	or	(iii)	the	bank	holding	company	will	not	meet,	
or	is	in	danger	of	not	meeting,	its	minimum	regulatory	
capital	adequacy	ratios.	

collateral	which	must	secure	such	extensions	of	credit	is	
regulated.

There	are	similar	legal	restrictions	on:	the	Bank’s	
purchases	of	or	investments	in	the	securities	of	and	
purchases	of	assets	from	us	or	our	nonbank	subsidiaries;	
the	Bank’s	loans	or	extensions	of	credit	to	third	parties	
collateralized	by	the	securities	or	obligations	of	us	or	our	
nonbank	subsidiaries;	the	issuance	of	guaranties,	
acceptances,	and	letters	of	credit	on	behalf	of	us	or	our	
nonbank	subsidiaries;	and	certain	bank	transactions	with	
us	or	our	nonbank	subsidiaries,	or	with	respect	to	which	
we	or	our	nonbank	subsidiaries	act	as	agent,	participate,	
or	have	a	financial	interest.	

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Capital Adequacy

Federal	financial	industry	regulators	require	that	regulated	
institutions	maintain	minimum	capital	levels.	The	capital	
rules	in	the	U.S.	are	based	on	international	standards	
known	as	“Basel	III.”	Those	U.S.	rules	require	the	
following:

• Common	Equity	Tier	1	Capital	Ratio.	For	all	supervised	
financial	institutions,	including	us	and	the	Bank,	the	
ratio	of	Common	Equity	Tier	1	Capital	to	risk-
weighted	assets	(“Common	Equity	Tier	1	Capital	
ratio”)	must	be	at	least	4.5%.	To	be	“well	capitalized”	
the	Common	Equity	Tier	1	Capital	ratio	must	be	at	
least	6.5%.	Common	Equity	Tier	1	Capital	consists	of	
core	components	of	Tier	1	Capital.	The	core	
components	consist	of	common	stock	plus	retained	
earnings	net	of	goodwill,	other	intangible	assets,	and	
certain	other	required	deduction	items.	At	
December	31,	2021,	our	Common	Equity	Tier	1	
Capital	Ratio	was	9.92%	and	the	Bank’s	was	10.75%.	

• Tier	1	Capital	Ratio.	For	all	supervised	financial	

institutions,	including	us	and	the	Bank,	the	ratio	of	
Tier	1	Capital	to	risk-weighted	assets	must	be	at	least	
6%.	To	be	“well	capitalized”	the	Tier	1	Capital	ratio	
must	be	at	least	8%.	Tier	1	Capital	consists	of	the	Tier	
1	core	components	discussed	in	the	bulleted	
paragraph	immediately	above,	plus	non-cumulative	
perpetual	preferred	stock,	a	limited	amount	of	
minority	interests	in	the	equity	accounts	of	
consolidated	subsidiaries,	and	a	limited	amount	of	
cumulative	perpetual	preferred	stock,	net	of	goodwill,	
other	intangible	assets,	and	certain	other	required	
deduction	items.	At	December	31,	2021,	our	Tier	1	
Capital	Ratio	was	11.04%	and	the	Bank’s	was	11.22%.

• Total	Capital	Ratio.	For	all	supervised	financial	

institutions,	including	us	and	the	Bank,	the	ratio	of	
Total	Capital	to	risk-weighted	assets	must	be	at	least	
8%.	To	be	“well	capitalized”	the	Total	Capital	ratios	
must	be	at	least	10%.	At	December	31,	2021,	our	
Total	Capital	Ratio	was	12.34%	and	the	Bank’s	was	
12.41%.

• Capital	Conservation	Buffer.	If	a	capital	conservation	
buffer	of	an	additional	2.5%	above	the	minimum	
required	Common	Equity	Tier	1	Capital	ratio,	Tier	1	
Capital	ratio,	and	Total	Capital	ratio	is	not	maintained,	
special	restrictions	would	apply	to	capital	
distributions,	such	as	dividends	and	stock	
repurchases,	and	on	certain	compensatory	bonuses.	

• Leverage	Ratio—Base.	For	all	supervised	financial	
institutions,	including	us	or	the	Bank,	the	Leverage	
ratio	must	be	at	least	4%.	To	be	“well	capitalized”	the	
Leverage	ratio	must	be	at	least	5%.	The	Leverage	ratio	
is	Tier	1	Capital	divided	by	quarterly	average	assets	
net	of	goodwill,	certain	other	intangible	assets,	and	
certain	required	deduction	items.	At	December	31,	

2021,	our	Leverage	ratio	was	8.08%	and	the	Bank’s	
was	8.20%.

• Leverage	Ratio—Supplemental.	For	the	largest	

internationally	active	supervised	financial	institutions,	
not	including	us	or	the	Bank,	a	minimum	
supplementary	Leverage	ratio	must	be	maintained	
that	takes	into	account	certain	off-balance	sheet	
exposures.

We	believe	that	we	and	the	Bank	were	in	compliance	with	
applicable	minimum	capital	requirements	as	of	
December	31,	2021.

Federal	regulators	have	incorporated	market	and	interest-
rate	risk	components	into	its	risk-based	capital	standards.	
Those	standards	explicitly	identify	concentration	of	credit	
risk	and	certain	risks	arising	from	non-traditional	activities,	
and	the	management	of	such	risks,	as	important	
qualitative	factors	to	consider	in	assessing	an	institution’s	
overall	capital	adequacy.

Federal	regulators’	market	risk	rules	are	applicable	to	
covered	institutions—those	with	aggregate	trading	assets	
and	trading	liabilities	of	at	least	10%	of	their	total	assets	
or	at	least	$1	billion.	We	and	the	Bank	are	covered	
institutions	under	the	rule.	The	rules	specify	the	
methodology	for	calculating	the	amount	of	risk-weighted	
assets	related	to	trading	assets	and	include,	among	other	
things,	the	addition	of	a	component	for	stressed	value	at	
risk.	The	rule	eliminates	the	use	of	credit	ratings	in	
calculating	specific	risk	capital	requirements	for	certain	
debt	and	securitization	positions.	Alternative	standards	of	
creditworthiness	are	used	for	specific	standardized	risks,	
such	as	exposures	to	sovereign	debt,	public	sector	
entities,	other	banking	institutions,	corporate	debt,	and	
securitizations.	In	addition,	an	8%	capital	surcharge	
applies	to	certain	covered	institutions,	not	including	us	or	
the	Bank.

Moreover,	the	Federal	Reserve	has	indicated	that	it	
considers	a	“Tangible	Tier	1	Capital	Leverage	
Ratio”	(deducting	all	intangibles)	and	other	indicators	of	
capital	strength	in	evaluating	proposals	for	expansion	or	
new	activities.

Failure	to	meet	capital	guidelines	could	subject	a	bank	to	a	
variety	of	enforcement	remedies,	including	the	
termination	of	deposit	insurance	by	the	FDIC,	and	to	
certain	restrictions	on	its	business	and	in	certain	
circumstances	to	the	appointment	of	a	conservator	or	
receiver.	See	Prompt	Corrective	Action	(PCA)	immediately	
below	for	additional	information.

In	addition,	the	Bank	is	required	to	have	a	capital	structure	
that	the	TDFI	determines	is	adequate,	based	on	TDFI’s	
assessment	of	the	Bank’s	businesses	and	risks.	The	TDFI	
may	require	the	Bank	to	increase	its	capital,	if	found	to	be	
inadequate.	

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Prompt Corrective Action (PCA)

Federal	banking	regulators	must	take	“prompt	corrective	
action”	regarding	FDIC-insured	depository	institutions	that	
do	not	meet	minimum	capital	requirements.	For	this	
purpose,	insured	depository	institutions	are	divided	into	

Table	1.10

five	capital	categories.	The	specific	requirements	
applicable	to	us	are	summarized	in	Table	1.10.	

REQUIREMENTS	FOR	PCA	CAPITALIZATION	CATEGORIES
• Common	Equity	Tier	1	Capital	ratio	of	at	least	6.5%
• Tier	1	Capital	ratio	of	at	least	8%
• Total	Capital	ratio	of	at	least	10%
• Leverage	ratio	of	at	least	5%
• Not	subject	to	a	directive,	order,	or	written	agreement	to	meet	and	

Well	capitalized

maintain	specific	capital	levels

Adequately	
capitalized

• Common	Equity	Tier	1	Capital	ratio	of	at	least	4.5%
• Tier	1	Capital	ratio	of	at	least	6%
• Total	Capital	ratio	of	at	least	8%
• Leverage	ratio	of	at	least	4%
• Not	subject	to	a	directive,	order,	or	written	agreement	to	meet	and	

maintain	specific	capital	levels

Undercapitalized

Failure	to	maintain	any	requirement	to	be	adequately	capitalized

Significantly	
Undercapitalized

Failure	to	maintain	Common	Equity	Tier	1	Capital	ratio	of	at	least	3%,	Tier	1	
Capital	ratio	of	at	least	4%,	Total	Capital	ratio	of	at	least	6%,	or	a	Leverage	
ratio	of	at	least	3%

Critically	
Undercapitalized

Failure	to	maintain	a	level	of	tangible	equity	equal	to	at	least	2%	of	total	
assets

At	December	31,	2021,	the	Bank	had	sufficient	capital	to	
qualify	as	“well	capitalized”	under	the	regulatory	capital	
requirements	discussed	above.	An	institution	may	be	
deemed	to	be	in	a	capitalization	category	that	is	lower	
than	is	indicated	by	its	actual	capital	position	if	it	receives	
an	unsatisfactory	examination	rating.	Institutions	
generally	are	not	allowed	to	publicly	disclose	examination	
results.

An	FDIC-insured	depository	institution	generally	is	
prohibited	from	making	any	capital	distribution	(including	
payment	of	dividends)	or	paying	any	management	fee	to	
its	holding	company	if	the	depository	institution	would	
thereafter	be	undercapitalized.	Undercapitalized	
depository	institutions	are	subject	to	restrictions	on	
borrowing	from	the	Federal	Reserve	System.	In	addition,	
undercapitalized	depository	institutions	are	subject	to	
growth	limitations	and	are	required	to	submit	capital	
restoration	plans.	An	insured	depository	institution’s	
holding	company	must	guarantee	the	capital	plan,	up	to	
an	amount	equal	to	the	lesser	of	5%	of	the	depository	
institution’s	assets	at	the	time	it	becomes	

Liquidity Coverage Ratio

The	liquidity	coverage	ratio,	or	LCR,	refers	to	the	amount	
of	liquid	assets	(cash,	cash	equivalents,	or	short-term	
securities)	banks	are	required	to	keep	on	hand	to	meet	a	
hypothetically	projected	total	net	cash	outflows	over	a	
forward-looking	30-day	period	of	stress.	The	stressed	
outflow	estimate	is	based	a	standard	set	of	hypothetical	
assumptions	set	forth	in	regulatory	requirements.	The	LCR	

undercapitalized	or	the	amount	of	the	capital	deficiency	
when	the	institution	fails	to	comply	with	the	plan,	for	the	
plan	to	be	accepted	by	the	applicable	federal	regulatory	
authority.	The	federal	banking	agencies	may	not	accept	a	
capital	plan	without	determining,	among	other	things,	
that	the	plan	is	based	on	realistic	assumptions	and	is	likely	
to	succeed	in	restoring	the	depository	institution’s	capital.	
If	a	depository	institution	fails	to	submit	an	acceptable	
plan,	it	is	treated	as	if	it	were	significantly	
undercapitalized.

Significantly	undercapitalized	depository	institutions	may	
be	subject	to	a	number	of	requirements	and	restrictions,	
including	orders	to	sell	sufficient	voting	stock	to	become	
adequately	capitalized,	requirements	to	reduce	total	
assets	and	cessation	of	receipt	of	deposits	from	
correspondent	banks.	

Critically	undercapitalized	depository	institutions	are	
subject	to	appointment	of	a	receiver	or	conservator,	
generally	within	90	days	of	the	date	on	which	they	
become	critically	undercapitalized.

is	designed	to	ensure	banks	hold	a	buffer	of	high-quality	
liquid	assets	so	that	they	can	meet	their	short-term	
liquidity	needs	and	remain	stable	and	strong	in	a	stressed	
environment.	Liquid	assets	generally	provide	low	income	
levels	compared	to	other	investments,	so	a	higher	LCR	
requirement	can	negatively	impact	a	bank's	earnings.

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The	LCR	requirement	does	not	apply	to	institutions	with	
assets	of	less	than	$100	billion,	and	so	does	not	apply	to	
us	or	the	Bank.	For	larger	institutions,	the	minimum	LCR	
requirement	increases	based	on	a	bank’s	asset	size.	

Category	IV	banks,	with	at	least	$100	billion	in	assets,	are	
not	subject	to	LCR	requirements	unless	they	have	at	least	
$50	billion	in	weighted	short-term	wholesale	funding.	

Holding Company Structure and Support of Subsidiary Banks

Because	we	are	a	holding	company,	our	right	to	
participate	in	the	assets	of	any	subsidiary	upon	the	latter’s	
liquidation	or	reorganization	will	be	subject	to	the	prior	
claims	of	the	subsidiary’s	creditors	(including	depositors	in	
the	case	of	the	Bank),	except	to	the	extent	that	we	may	be	
a	creditor	with	recognized	claims	against	the	subsidiary.	In	
addition,	depositors	of	a	bank,	and	the	FDIC	as	their	
subrogee,	would	be	entitled	to	priority	over	the	other	
creditors	in	the	event	of	liquidation	of	the	bank.

Under	Federal	Reserve	policy	we	are	expected	to	act	as	a	
source	of	financial	strength	to,	and	to	commit	resources	to	

Cross-Guarantee Liability

A	depository	institution	insured	by	the	FDIC	can	be	held	
liable	for	any	loss	incurred	by,	or	reasonably	expected	to	
be	incurred	by,	the	FDIC	in	connection	with	(i)	the	default	
of	a	commonly	controlled	FDIC-insured	depository	
institution	or	(ii)	any	assistance	provided	by	the	FDIC	to	
any	commonly	controlled	FDIC-insured	depository	
institution	“in	danger	of	default.”		“Default”	is	defined	
generally	as	the	appointment	of	a	conservator	or	receiver	
and	“in	danger	of	default”	is	defined	generally	as	the	
existence	of	certain	conditions	indicating	that	a	default	is	
likely	to	occur	in	the	absence	of	regulatory	assistance.	The	
FDIC’s	claim	for	damages	is	superior	to	claims	of	
shareholders	of	the	insured	depository	institution	or	its	

Interstate Branching & Mergers

As	mentioned	above,	the	Bank	generally	must	have	TDFI’s	
approval	to	establish	a	new	banking	center	(technically,	a	
“branch”).	For	a	new	banking	center	located	outside	of	
Tennessee,	Tennessee	law	requires	the	Bank	to	comply	
with	branching	laws	applicable	to	the	state	where	the	new	
banking	center	will	be	located.	Federal	law	allows	the	
Bank	to	establish	or	acquire	a	branch	in	another	state	to	
the	same	extent	as	a	bank	chartered	in	that	other	state	
would	be	allowed	to	establish	or	acquire	a	branch	in	
Tennessee.	

For	an	interstate	merger	or	acquisition:		the	acquiring	
bank	must	be	well-capitalized	and	well-managed;	
concentration	limits	on	liabilities	and	deposits	may	not	be	

Community Reinvestment Act (“CRA”)

The	CRA	requires	each	U.S.	bank,	consistent	with	safe	and	
sound	operation,	to	help	meet	the	credit	needs	of	each	
community	where	the	bank	accepts	deposits,	including	
low-	and	moderate-income	(“LMI”)	communities.	The	
Federal	Reserve	assesses	the	Bank	periodically	for	CRA	

support,	the	Bank.	This	support	may	be	required	at	times	
even	if,	absent	such	Federal	Reserve	policy,	we	might	not	
wish	to	provide	it.	In	addition,	any	capital	loans	by	a	bank	
holding	company	to	any	of	its	subsidiary	banks	are	
subordinate	in	right	of	payment	to	deposits	and	to	certain	
other	indebtedness	of	the	subsidiary	bank.	In	the	event	of	
a	bank	holding	company’s	bankruptcy,	any	commitment	
by	the	bank	holding	company	to	a	federal	bank	regulatory	
agency	to	maintain	the	capital	of	a	subsidiary	bank	will	be	
assumed	by	the	bankruptcy	trustee	and	entitled	to	a	
priority	of	payment.

holding	company	but	is	subordinate	to	claims	of	
depositors,	secured	creditors,	and	holders	of	subordinated	
debt	(other	than	affiliates)	of	the	commonly	controlled	
insured	depository	institution.	

Currently	the	Bank	is	our	only	depository	institution	
subsidiary.	If	we	were	to	own	or	operate	another	
depository	institution,	any	loss	suffered	by	the	FDIC	in	
respect	of	one	subsidiary	bank	would	likely	result	in	
assertion	of	the	cross-guarantee	provisions,	the	
assessment	of	estimated	losses	against	our	other	
subsidiary	bank(s),	and	a	potential	loss	of	our	investment	
in	our	subsidiary	banks.

exceeded;	regulators	must	assess	the	transaction	for	
incremental	systemic	risk;	and	the	acquiring	bank	must	
have	at	least	“satisfactory”	standing	under	the	federal	
Community	Reinvestment	Act	(discussed	immediately	
below).

Once	a	bank	has	established	branches	in	a	state	through	
de	novo	or	acquired	branching	or	through	an	interstate	
merger	transaction,	the	bank	may	then	establish	or	
acquire	additional	branches	within	that	state	to	the	same	
extent	that	a	bank	chartered	in	that	state	is	allowed	to	
establish	or	acquire	branches	within	the	state.

compliance,	and	that	assessment	is	made	public.	The	
Bank’s	LMI	operations	and	activities	traditionally	are	
critical	focal	points	in	those	assessments.	

A	CRA	rating	below	“satisfactory”	can	slow	or	halt	a	bank’s	
plans	to	expand	by	branching,	acquisition,	or	merger,	and	

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can	prevent	a	bank	holding	company	from	becoming	a	
financial	holding	company.	In	its	most	recent	CRA	
assessment,	for	2020,	the	Bank	received	ratings	of	"High	

Financial Activities other than Banking

Federal	Law

Federal	law	generally	allows	financial	holding	companies	
broad	authority	to	engage	in	activities	that	are	financial	in	
nature	or	incidental	to	a	financial	activity.	These	include:	
insurance	underwriting	and	brokerage;	merchant	banking;	
securities	underwriting,	dealing,	and	market-making;	real	
estate	development;	and	such	additional	activities	as	the	
Federal	Reserve	in	consultation	with	the	Secretary	of	the	
Treasury	determines	to	be	financial	in	nature	or	
incidental.	A	bank	holding	company	may	engage	in	these	
activities	directly	or	through	subsidiaries	by	qualifying	as	a	
“financial	holding	company.”	To	qualify	as	a	financial	
holding	company,	a	bank	holding	company	must	file	an	
initial	declaration	with	the	Federal	Reserve,	certifying	that	
all	of	its	subsidiary	depository	institutions	are	well-
managed	and	well-capitalized.	

Federal	law	also	permits	banks	to	engage	in	certain	of	
these	activities	through	financial	subsidiaries.	To	control	
or	hold	an	interest	in	a	financial	subsidiary,	a	bank	must	
meet	the	following	requirements:	

(1)	 The	bank	must	receive	approval	from	its	primary	
federal	regulator	for	the	financial	subsidiary	to	
engage	in	the	activities.	

(2)	 The	bank	and	its	depository	institution	affiliates	must	

each	be	well-capitalized	and	well-managed.

(3)	 The	aggregate	consolidated	total	assets	of	all	of	the	
bank’s	financial	subsidiaries	must	not	exceed	the	
lesser	of:	45%	of	the	bank’s	consolidated	total	assets;	
or	$50	billion	(subject	to	indexing	for	inflation).

(4)	 The	bank	must	have	in	place	adequate	policies	and	
procedures	to	identify	and	manage	financial	and	
operational	risks	and	to	preserve	the	separate	
identities	and	limited	liability	of	the	bank	and	the	
financial	subsidiary.	

(5)	 If	the	bank	is	among	the	100	largest	banks,	the	bank	
must	meet	the	long-term	debt	rating	or	alternative	

Interchange Fee Restrictions

Satisfactory"	in	Lending	and	in	Service,	"Outstanding"	in	
Investment,	and	"Satisfactory"	overall.	

standards	adopted	by	the	Federal	Reserve	and	the	
U.S.	Secretary	of	the	Treasury	from	time	to	time.	If	
this	fifth	requirement	ceases	to	be	met	after	a	bank	
controls	or	holds	an	interest	in	a	financial	subsidiary,	
the	bank	cannot	invest	additional	capital	in	that	
subsidiary	until	the	requirement	again	is	met.

No	new	activity	may	be	commenced	unless	the	bank	and	
all	of	its	depository	institution	affiliates	have	at	least	
“satisfactory”	CRA	ratings.	Certain	restrictions	apply	if	the	
bank	holding	company	or	the	bank	fails	to	continue	to	
meet	one	or	more	of	the	requirements	listed	above.	

In	addition,	federal	law	contains	a	number	of	other	
provisions	that	may	affect	the	Bank’s	operations,	including	
limitations	on	the	use	and	disclosure	to	third	parties	of	
client	information.	

At	December	31,	2021,	we	are	a	financial	holding	
company	and	the	Bank	has	a	number	of	financial	
subsidiaries,	as	discussed	in	Subsidiaries	within	this	Item	1	
under	the	Other	Business	Information	discussion,	which	
begins	on	page	18.	

Tennessee	Law

Tennessee	law	does	not	expressly	restrict	the	activities	of	
a	bank	holding	company	or	its	non-bank	affiliates.	
However,	no	Tennessee	bank	may	maintain	a	branch	
office	on	the	premises	of	an	affiliate	if	the	affiliate	is	
engaged	in	activities	that	are	not	permissible	for	a	bank	
holding	company,	a	financial	holding	company,	a	national	
bank,	or	a	national	bank	subsidiary	under	federal	law.	
Tennessee	law	permits	Tennessee	banks	to	establish	
subsidiaries	and	to	engage	in	any	activities	permissible	for	
a	national	bank	located	in	Tennessee,	subject	to	
compliance	with	Tennessee	regulations	relating	to	the	
conduct	of	such	activities	for	the	purpose	of	maintaining	
bank	safety	and	soundness.

Regulations	severely	cap	interchange	fees	which	the	Bank	may	charge	merchants	for	debit	card	transactions.	

Volcker Rule

The	Volcker	rule	(1)	generally	prohibits	banks	from	
engaging	in	proprietary	trading,	which	is	engaging	as	
principal	(for	the	bank’s	own	account)	in	any	purchase	or	
sale	of	one	or	more	of	certain	types	of	financial	

instruments,	and	(2)	limits	banks’	ability	to	invest	in	or	
sponsor	hedge	funds	or	private	equity	funds.			

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Consumer Regulation by the CFPB

The	CFPB	adopts	and	administers	significant	rules	
affecting	consumer	lending	and	consumer	financial	
services.	Key	rules	for	the	Bank	include	detailed	regulation	
of	mortgage	servicing	practices	and	detailed	regulation	of	
mortgage	origination	and	underwriting	practices.	The	
latter	rules,	among	other	things,	establish	the	definition	of	

Data Security & Portability

Security	&	Privacy

Federal	law	requires	banks	to	implement	a	comprehensive	
information	security	program	that	includes	administrative,	
technical,	and	physical	safeguards.	Banks	are	required	to	
have	appropriate	data	governance	practices	and	risk	
management	processes	as	key	functions	supporting	its	
operational	resilience.

Data	privacy	and	protection	increasingly	is	a	significant	
legislative,	regulatory,	and	societal	concern.	The	concern	
is	driven	by	major	technological	and	societal	shifts	in	the	
past	20	years,	led	by	relatively	unregulated	firms	such	as	
Amazon.com,	Alibaba,	Facebook,	and	Google	and	their	
many	clients	worldwide.	Those	firms	have	gathered	large	
amounts	of	personal	details	about	millions	of	people,	and	
today	have	the	ability	to	analyze	that	data	and	act	on	that	
analysis	very	quickly.	These	firms	seek	to	understand	
enough	about	a	person	to	know	what	a	person	wants	
before	the	person	does.	

Banks	(as	mentioned	above)	already	are	subject	to	
significant	privacy	regulations.	Probably	for	that	reason,	
the	banking	industry	is	not	at	the	political	center	of	these	
concerns	today.	Even	so,	banks	are	likely	to	be	affected	by	
broader	legislative	and	regulatory	responses	to	the	
perceived	problems.	Two	prominent	responses	to	date	

FDIC Insurance Assessments; DIFA

U.S.	bank	deposits	generally	are	insured	by	the	Deposit	
Insurance	Fund	(“DIF”),	administered	by	the	FDIC.	The	
system	of	FDIC	insurance	premium	rates	charged	consists	
of	a	rate	grid	structure	in	which	base	rates	range	from	5	to	
35	basis	points	annually,	and	fully	adjusted	rates	range	
from	2.5	to	45	basis	points	annually.	(A	basis	point	is	equal	
to	0.01%.)	Key	factors	in	the	grid	include:		the	institution’s	
risk	category	(I	to	IV);	whether	the	institution	is	deemed	
large	and	highly	complex;	whether	the	institution	qualifies	
for	an	unsecured	debt	adjustment;	and	whether	the	
institution	is	burdened	with	a	brokered	deposit	

Depositor Preference

Federal	law	provides	that	deposits	and	certain	claims	for	
administrative	expenses	and	associate	compensation	
against	an	insured	depository	institution	would	be	
afforded	a	priority	over	other	general	unsecured	claims	

a	“qualified	mortgage”	using	traditional	underwriting	
practices	involving	down	payments,	credit	history,	income	
levels	and	verification,	and	so	forth.	The	rules	do	not	
prohibit,	but	do	tend	to	discourage,	lenders	from	
originating	non-qualified	mortgages.	

include	the	European	Union	General	Data	Protection	
Regulation	and	the	California	Data	Privacy	Protection	Act.	
Neither	is	a	banking	industry	regulation,	but	both	apply	to	
banks	in	relation	to	certain	clients.	To	date,	neither	has	
had	a	material	impact	on	the	Bank.	

Portability	&	Client	Control	

Federal	law	restricts	the	Bank’s	ability	to	share	certain	
information	with	affiliates	and	non-affiliates	for	marketing	
and/or	non-marketing	purposes,	or	to	contact	clients	with	
marketing	offers.	Affiliate	and	non-affiliate	sharing	
initiated	by	the	Bank	generally	is	permitted	with	client	
consent.

Increasingly,	banks	are	being	required	to	permit,	enable,	
and	support	client	control	of	client	data,	including	the	
sharing	of	client	data	with	Bank	affiliates	and	with	outside	
organizations.	These	requirements,	which	still	are	
evolving,	are	intended	to	foster	data	portability	for	clients	
and	greater	competition	among	financial	services	firms.	
However,	they	also	significantly	increase	data	security	
risks	because	they	create	additional	access	channels	for	
bad	actors	to	try	to	exploit,	or	they	make	accessing	
existing	channels	easier	or	faster.

adjustment.	Other	factors	can	impact	the	base	against	
which	the	applicable	rate	is	applied,	including	(for	
example)	whether	a	net	loss	is	realized.	

Insurance	of	deposits	may	be	terminated	by	the	FDIC	
upon	a	finding	that	the	institution	has	engaged	in	unsafe	
and	unsound	practices,	is	in	an	unsafe	or	unsound	
condition	to	continue	operations,	or	has	violated	any	
applicable	law,	regulation,	rule,	order,	or	condition	
imposed	by	a	federal	bank	regulatory	agency.

against	such	an	institution,	including	federal	funds	and	
letters	of	credit,	in	the	“liquidation	or	other	resolution”	of	
such	an	institution	by	any	receiver.

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Securities Regulation

Certain	of	our	subsidiaries	are	subject	to	various	securities	
laws	and	regulations	and	capital	adequacy	requirements	
promulgated	by	the	regulatory	and	exchange	authorities	
of	the	jurisdictions	in	which	they	operate.

Our	registered	broker-dealer	subsidiaries	are	subject	to	
the	SEC’s	net	capital	rule,	Rule	15c3-1.	That	rule	requires	
the	maintenance	of	minimum	net	capital	and	limits	the	
ability	of	the	broker-dealer	to	transfer	large	amounts	of	
capital	to	a	parent	company	or	affiliate.	Compliance	with	

Insurance Activities

Certain	of	our	subsidiaries	sell	various	types	of	insurance	
as	agent	in	a	number	of	states.	Insurance	activities	are	
subject	to	regulation	by	the	states	in	which	such	business	
is	transacted.	Although	most	of	such	regulation	focuses	on	
insurance	companies	and	their	insurance	products,	

Compensation & Risk Management

The	Federal	Reserve	has	issued	guidance	intended	to	
ensure	that	incentive	compensation	arrangements	at	
financial	organizations	take	into	account	risk	and	are	
consistent	with	safe	and	sound	practices.	The	guidance	is	
based	on	three	“key	principles”	calling	for	incentive	
compensation	plans	to:		appropriately	balance	risks	and	
rewards;	be	compatible	with	effective	controls	and	risk	
management;	and	be	backed	up	by	strong	corporate	
governance.	In	response:	we	operate	an	enhanced	risk	
management	process	for	assessing	risk	in	incentive	
compensation	plans;	several	key	incentive	programs	use	a	
net	profit	approach	rather	than	a	revenues-only	approach;	
and	mandatory	deferral	features	are	used	in	several	key	
programs,	including	an	executive	program.

In	2016	federal	agencies	proposed	regulations	which	could	
significantly	change	the	regulation	of	incentive	
compensation	programs	at	financial	institutions.	The	

the	rule	could	limit	operations	that	require	intensive	use	
of	capital,	such	as	underwriting	and	trading.

Certain	of	our	subsidiaries	are	registered	investment	
advisers	which	are	regulated	under	the	Investment	
Advisers	Act	of	1940.	Advisory	contracts	with	clients	
automatically	terminate	under	these	laws	upon	an	
assignment	of	the	contract	by	the	investment	adviser	
unless	appropriate	consents	are	obtained.

insurance	agents	and	their	activities	are	also	subject	to	
regulation	by	the	states,	including,	among	other	things,	
licensing	and	marketing	and	sales	practices.	

proposal	would	create	four	tiers	of	institutions	based	on	
asset	size.	Institutions	in	the	top	two	tiers	would	be	
subject	to	rules	much	more	detailed	and	proscriptive	than	
are	currently	in	effect.	If	interpreted	aggressively	by	the	
regulators,	the	proposed	rules	could	be	used	to	prevent,	
as	a	practical	matter,	larger	institutions	from	engaging	in	
certain	lines	of	business	where	substantial	commission	
and	bonus	pool	arrangements	are	the	norm.	In	the	2016	
proposal,	the	top	two	tiers	included	institutions	with	more	
than	$50	billion	of	assets.	We	and	the	Bank	currently	
would	fall	into	the	lower	of	those	top	two	tiers.	However,	
prompted	by	post-2016	legislation	which	significantly	
raised	several	statutory	asset-size	tiers,	if	this	proposal	
were	finalized	today,	the	$50	billion	floor	might	be	raised	
significantly,	allowing	us	to	remain	in	the	third	tier.	We	
cannot	predict	what	final	rules	may	be	adopted,	nor	how	
they	may	be	implemented.

Effect of Government Policies & Proposals

The	Bank	is	affected	by	the	policies	of	regulatory	
authorities,	including	the	Federal	Reserve,	the	TDFI,	and	
the	CFPB.	See	Supervision	and	Regulation	beginning	on	
page	21	for	additional	information.	

The	Federal	Reserve	also	sets	and	manages	monetary	
policy	for	the	U.S.	In	this	latter	role,	the	Federal	Reserve’s	
mandate	from	Congress	is	to	pursue	price	stability	and	full	
employment.	

Among	the	instruments	of	monetary	policy	used	by	the	
Federal	Reserve	are:	purchases	and	sales	of	U.S.	
government	and	other	securities	in	the	marketplace;	
changes	in	the	discount	rate,	which	is	the	rate	any	
depository	institution	must	pay	to	borrow	from	the	
Federal	Reserve;	changes	in	the	reserve	requirements	of	

depository	institutions;	changes	in	the	rate	paid	on	banks’	
required	and	excess	reserve	deposits	at	the	Federal	
Reserve;	and	changes	in	the	federal	funds	rate,	which	is	
the	rate	at	which	depository	institutions	lend	balances	to	
each	other	overnight.	These	instruments	are	intended	to	
influence	economic	and	monetary	growth,	interest	rate	
levels,	and	inflation.

The	monetary	policies	of	the	Federal	Reserve	and	other	
governmental	policies	have	had	a	significant	effect	on	the	
operating	results	of	commercial	banks	in	the	past	and	are	
expected	to	continue	to	do	so	in	the	future.	Because	of	
changing	conditions	in	the	national	and	international	
economies	and	in	the	money	markets,	as	well	as	the	result	
of	actions	by	monetary	and	fiscal	authorities,	it	is	not	
possible	to	predict	with	certainty	future	changes	in	

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ITEM	1.	BUSINESS

Table	of	Contents

interest	rates,	deposit	levels,	loan	demand,	or	the	
business	and	results	of	our	operations,	or	whether	
changing	economic	conditions	will	have	a	positive	or	
negative	effect	on	operations	and	earnings.	Additional	
information	concerning	monetary	policy	changes	appears:		
under	the	caption	Monetary	Policy	Shifts	within	the	
Significant	Business	Developments	section	of	Item	1,	
which	begins	on	page	12;	under	the	caption	Risks	
Associated	with	Monetary	Events	beginning	on	page	38	
within	Item	1A;	and	under	the	caption	Federal	Reserve	
Policy	in	Transition	within	the	Market	Uncertainties	and	
Prospective	Trends	section	of	our	2021	MD&A	(Item	7),	
which	begins	on	page	99.

Sources & Availability of Funds

Bills	occasionally	are	introduced	in	the	United	States	
Congress,	the	Tennessee	General	Assembly	and	other	
state	legislatures,	and	regulations	occasionally	are	
proposed	by	our	regulatory	agencies,	any	of	which	could	
affect	our	businesses,	financial	results,	and	financial	
condition.	

We	are	not	able	to	predict	what,	if	any,	changes	that	
Congress,	state	legislatures,	or	the	regulatory	agencies	will	
enact	or	implement	in	the	future,	nor	the	impact	that	
those	actions	will	have	upon	us.

Information	concerning	the	sources	and	availability	of	funds	for	our	businesses	can	be	found	in	our	2021	MD&A	(Item	7),	
including	the	subsection	entitled	Liquidity	Risk	Management	beginning	on	page	95,	which	material	is	incorporated	herein	by	
reference.

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ITEM	1A.	RISK	FACTORS

Table	of	Contents

Item 1A. Risk Factors

This	Item	outlines	specific	risks	that	could	affect	the	ability	
of	our	various	businesses	to	compete,	change	our	risk	
profile,	or	materially	impact	our	operating	results	or	
financial	condition.	Our	operating	environment	continues	
to	evolve	and	new	risks	continue	to	emerge.	To	address	
that	challenge	we	have	a	risk	management	governance	
structure	that	oversees	processes	for	monitoring	evolving	
risks	and	oversees	various	initiatives	designed	to	manage	
and	control	our	potential	exposure.

This	Item	highlights	risks	that	could	impact	us	in	material	
ways	by	causing	future	results	to	differ	materially	from	

past	results,	by	causing	future	results	to	differ	materially	
from	current	expectations,	or	by	causing	material	changes	
in	our	financial	condition.	In	this	Item	we	have	outlined	
risks	that	we	believe	are	important	to	us	at	the	present	
time.	However,	other	risks	may	prove	to	be	important	in	
the	future,	and	new	risks	may	emerge	at	any	time.	We	
cannot	predict	all	potential	developments	that	could	
materially	affect	our	financial	performance	or	condition.

Topic

Risks	related	to	the	Proposed	TD	Merger

Traditional	Competition	Risks

Traditional	Strategic	&	Macro	Risks

Industry	Disruption

Operational	Risks

Risks	from	Economic	Downturns	&	Changes

Risks	Associated	with	Monetary	Events

Risks	Related	to	Businesses	We	May	Exit

Reputation	Risks

Credit	Risks

Service	Risks

Risks	related	to	COVID-19	Pandemic

TABLE	OF	ITEM	1A	TOPICS

Page

Topic

31

33

34

35

36

38

38

39

40

40

42

42

Regulatory,	Legislative,	and	Legal	Risks

Risks	of	Expense	Control

Geographic	Risks

Insurance

Liquidity	&	Funding	Risks

Credit	Ratings

Interest	Rate	&	Yield	Curve	Risks

Asset	Inventories	&	Market	Risks

Mortgage	Business	Risks

Pre-2009	Mortgage	Business	Risks

Accounting	&	Tax	Risks

Share	Owning	&	Governance	Risks

	Page

43

45

45

46

46

47

48

49

50

51

51

52

Risks Related to the Proposed TD Merger

The	announcement	and	pendency	of	the	Proposed	TD	
Merger	may	adversely	affect	our	business,	financial	
condition,	and	results	of	operations.	Uncertainty	about	
the	effect	of	the	Proposed	TD	Merger	on	our	associates,	
clients,	and	other	parties	may	have	an	adverse	effect	on	
our	business,	financial	condition,	and	results	of	operations	
regardless	of	whether	the	Proposed	TD	Merger	is	
completed.	These	risks	to	our	business	include,	among	
others,	the	following,	all	of	which	may	be	exacerbated	by	
a	delay	in	the	completion	of	the	Proposed	TD	Merger:	(i)	
the	impairment	of	our	ability	to	attract,	retain,	and	
motivate	its	employees;	(ii)	the	diversion	of	significant	
management	time	and	attention	from	ongoing	business	
operations	towards	the	completion	of	the	Proposed	TD	
Merger;	(iii)	difficulties	maintaining	relationships	with	
clients,	suppliers	and	other	business	partners;	(iv)	delays	
or	deferments	of	certain	business	decisions	by	our	clients,	
suppliers	and	other	business	partners;	(v)	the	inability	to	
pursue	alternative	business	opportunities	or	make	

appropriate	changes	to	our	business	because	the	TD	
Merger	Agreement	requires	us	to,	subject	to	certain	
exceptions,	conduct	its	business	in	the	ordinary	course	of	
business	and	to	not	engage	in	certain	kinds	of	transactions	
prior	to	the	completion	of	the	Proposed	TD	Merger	
without	the	prior	written	consent	of	TD	(such	consent	not	
to	be	unreasonably	conditioned,	withheld	or	delayed),	
even	if	such	actions	could	prove	beneficial;	(vi)	litigation	
relating	to	the	Proposed	TD	Merger	and	the	costs	and	
uncertainties	related	thereto;	and	(vii)	the	incurrence	of	
significant	costs,	expenses,	and	fees	for	professional	
services	and	other	transaction	costs	in	connection	with	
the	Proposed	TD	Merger.

Regulatory	approvals	may	not	be	received,	may	take	
longer	than	expected,	or	may	impose	conditions	that	are	
not	presently	anticipated.	Before	the	Proposed	TD	
Merger	may	be	completed,	various	approvals,	consents,	
and	non-objections	must	be	obtained	from	the	Federal	

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Reserve	and	various	other	bank	regulatory,	antitrust,	and	
other	authorities	in	the	United	States.	In	determining	
whether	to	grant	these	approvals,	such	regulatory	
authorities	consider	a	variety	of	factors,	including	the	
regulatory	standing	of	each	party.	These	approvals	could	
be	delayed	or	not	obtained	at	all,	including	due	to:	an	
adverse	development	in	either	party’s	regulatory	standing	
or	in	any	other	factors	considered	by	regulators	when	
granting	such	approvals;	governmental,	political	or	
community	group	inquiries,	investigations	or	opposition;	
or	changes	in	legislation	or	the	political	environment	
generally.	The	Federal	Reserve	has	stated	that	if	material	
weaknesses	are	identified	by	examiners	before	a	banking	
organization	applies	to	engage	in	expansionary	activity,	
the	Federal	Reserve	will	expect	the	banking	organization	
to	resolve	all	such	weaknesses	before	applying	for	such	
expansionary	activity.	The	Federal	Reserve	has	also	stated	
that	if	issues	arise	during	the	processing	of	an	application	
for	expansionary	activity,	it	will	expect	the	applicant	
banking	organization	to	withdraw	its	application	pending	
resolution	of	any	supervisory	concerns.

The	approvals	that	are	granted	may	impose	terms	and	
conditions,	limitations,	obligations,	or	costs,	or	may	place	
restrictions	on	the	conduct	of	the	combined	company’s	
business,	or	may	require	changes	to	the	terms	of	the	
transactions	contemplated	by	the	TD	Merger	Agreement	
and	related	bank	merger	agreement.	There	can	be	no	
assurance	that	regulators	will	not	impose	any	such	
conditions,	limitations,	obligations	or	restrictions	and	that	
such	conditions,	limitations,	obligations	or	restrictions	will	
not	have	the	effect	of	delaying	the	completion	of	any	of	
the	transactions	contemplated	by	the	TD	Merger	
Agreement	and	Bank	Merger	Agreement,	imposing	
additional	material	costs	on	us.	In	addition,	there	can	be	
no	assurance	that	any	such	conditions,	terms,	obligations	
or	restrictions	will	not	result	in	the	delay	or	abandonment	
of	the	Proposed	TD	Merger.	Additionally,	the	completion	
of	the	Proposed	TD	Merger	is	conditioned	on	the	absence	
of	certain	orders,	injunctions,	or	decrees	by	any	court	or	
regulatory	agency	of	competent	jurisdiction	that	would	
prohibit	or	make	illegal	the	completion	of	any	of	the	
transactions	contemplated	by	the	TD	Merger	Agreement	
and	related	bank	merger	agreement.

In	addition,	despite	the	parties’	commitments	to	use	their	
reasonable	best	efforts	to	comply	with	conditions	
imposed	by	regulators,	under	the	terms	of	TD	Merger	
Agreement	and	related	bank	merger	agreement,	neither	
us	nor	TBD	will	be	required,	and	neither	party	will	be	
permitted	without	the	prior	written	consent	of	the	other	
party,	to	take	actions	or	agree	to	conditions	that	would	
reasonably	be	expected	to	have	a	material	adverse	effect	
on	the	combined	company	and	its	subsidiaries,	taken	as	a	
whole,	after	giving	effect	to	the	mergers.

The	TD	Merger	Agreement	may	be	terminated	in	
accordance	with	its	terms,	and	the	Proposed	TD	Merger	
may	not	be	completed.	The	TD	Merger	Agreement	is	

subject	to	a	number	of	conditions	which	must	be	fulfilled	
in	order	to	complete	the	Proposed	TD	Merger.	Those	
conditions	include:	(i)	the	approval	of	the	Proposed	TD	
Merger	by	the	requisite	vote	of	our	shareholders;	(ii)	the	
receipt	of	all	required	regulatory	approvals	which	are	
necessary	to	close	the	Proposed	TD	Merger	and	the	
expiration	of	all	statutory	waiting	periods	without	the	
imposition	of	any	materially	burdensome	regulatory	
condition;	(iii)	the	absence	of	any	order,	injunction,	
decree,	or	other	legal	restraint	preventing	the	completion	
of	the	Proposed	TD	Merger	or	any	of	the	other	
transactions	contemplated	by	the	TD	Merger	Agreement	
or	by	the	related	bank	merger	agreement,	or	making	the	
completion	of	the	Proposed	TD	Merger	illegal;	(iv)	subject	
to	certain	exceptions,	the	accuracy	of	the	representations	
and	warranties	of	each	party,	generally	subject	to	a	
material	adverse	effect	qualification;	and	(v)	the	prior	
performance	in	all	material	respects	by	each	party	of	the	
obligations	required	to	be	performed	by	it	at	or	prior	to	
the	closing	date.

These	conditions	to	the	closing	may	not	be	fulfilled	in	a	
timely	manner	or	at	all,	and,	accordingly,	the	Proposed	TD	
Merger	may	not	be	completed.	In	addition,	the	parties	can	
mutually	decide	to	terminate	TD	Merger	Agreement	at	
any	time,	before	or	after	shareholder	approval.	Also,	
either	TD	or	we	may	elect	unilaterally	to	terminate	the	TD	
Merger	Agreement	in	certain	circumstances.

Failure	to	complete	the	Proposed	TD	Merger	could	
negatively	impact	us.	If	the	Proposed	TD	Merger	is	not	
completed	for	any	reason,	including	as	a	result	of	our	
shareholders	failing	to	approve	the	Proposed	TD	Merger	
or	as	a	result	of	failure	to	obtain	all	needed	regulatory	
approvals,	there	may	be	various	adverse	consequences	
and	we	may	experience	negative	reactions	from	the	
financial	markets	and	from	our	clients	and	associates.	

For	example,	our	business	may	be	impacted	adversely	by	
the	failure	to	pursue	other	beneficial	opportunities	due	to	
the	focus	of	management	on	the	Proposed	TD	Merger.	
Additionally,	if	the	TD	Merger	Agreement	is	terminated,	
the	market	price	of	our	common	stock	could	decline	
because,	after	announcement	of	the	Proposed	TD	Merger,	
we	expect	our	market	price	to	reflect	the	consideration	to	
be	paid	under	the	TD	Merger	Agreement;	a	termination	of	
the	Proposed	TD	Merger	would	likely	have	a	negative	
effect	on	our	market	price.	We	also	could	be	subject	to	
litigation	related	to	any	failure	to	complete	the	Proposed	
TD	Merger	or	to	proceedings	commenced	against	us	to	
perform	our	obligations	under	the	TD	Merger	Agreement.	
If	the	TD	Merger	Agreement	is	terminated	under	certain	
circumstances,	we	may	be	required	to	pay	to	TD	a	
termination	fee	of	up	to	$435.5	million.

Additionally,	we	expect	to	incur	substantial	expenses	in	
connection	with	the	negotiation	and	completion	of	the	
transactions	contemplated	by	the	TD	Merger	Agreement	
and	related	bank	merger	agreement,	as	well	as	the	costs	

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Table	of	Contents

and	expenses	of	preparing,	filing,	printing,	and	mailing	a	
proxy	statement,	and	all	filing	and	other	fees	paid	in	
connection	with	the	Proposed	TD	Merger.	If	the	Proposed	
TD	Merger	is	not	completed,	we	would	have	to	pay	a	large	
portion	of	these	expenses	without	realizing	the	expected	
benefits	of	the	Proposed	TD	Merger.

We	will	be	subject	to	business	uncertainties	and	
contractual	restrictions	while	the	Proposed	TD	Merger	is	
pending.	Uncertainty	about	the	effect	of	the	Proposed	TD	
Merger	on	associates	and	clients	may	have	an	adverse	
effect	on	us.	These	uncertainties	may	impair	our	ability	to	
attract,	retain	and	motivate	key	personnel	until	the	
Proposed	TD	Merger	is	completed,	and	could	cause	clients	
and	others	that	deal	with	us	to	seek	to	change	existing	
business	relationships	with	us.	In	addition,	subject	to	
certain	exceptions,	we	have	agreed	to	operate	our	
business	in	the	ordinary	course	prior	to	the	closing,	and	
we	are	restricted	from	making	certain	acquisitions	and	
taking	other	specified	actions	without	the	consent	of	TD	
until	the	Proposed	TD	Merger	is	completed.	These	
restrictions	may	prevent	us	from	pursuing	attractive	
business	opportunities	that	may	arise	prior	to	the	
completion	of	the	Proposed	TD	Merger.

The	TD	Merger	Agreement	contain	provisions	that	could	
discourage	a	potential	competing	acquirer	that	might	be	
willing	to	pay	more	to	acquire	or	merge	with	us.	The	TD	
Merger	Agreement	contains	provisions	that	restrict	our	
ability	to,	among	other	things,	initiate,	solicit,	knowingly	
encourage	or	knowingly	facilitate,	inquiries	or	proposals	
with	respect	to,	or,	subject	to	certain	exceptions	generally	
related	to	the	exercise	of	fiduciary	duties	by	our	board	of	
directors,	engage	in	any	negotiations	concerning,	or	
provide	any	confidential	or	nonpublic	information	or	data	
relating	to,	any	alternative	acquisition	proposals.	These	
provisions,	which	include	a	termination	fee	of	up	to	

Traditional Competition Risks

We	are	subject	to	intense	competition	for	clients,	and	
the	nature	of	that	competition	is	changing	quickly.	Our	
primary	areas	of	competition	include:	consumer	and	
commercial	deposits,	commercial	loans,	consumer	loans	
including	home	mortgages	and	lines	of	credit,	financial	
planning	and	wealth	management,	fixed	income	products	
and	services,	title	insurance	services,	and	other	consumer	
and	commercial	financial	products	and	services.	Our	
competitors	in	these	areas	include	national,	state,	and	
non-US	banks,	savings	and	loan	associations,	credit	
unions,	consumer	finance	companies,	trust	companies,	
investment	counseling	firms,	money	market	and	other	
mutual	funds,	insurance	companies	and	agencies,	
securities	firms,	mortgage	banking	companies,	hedge	
funds,	and	other	financial	services	companies	that	serve	in	
our	markets.	The	emergence	of	non-traditional,	disruptive	
service	providers	(see	Industry	Disruption	within	this	Item	

$435.5	million	payable	by	us	under	certain	circumstances,	
might	discourage	a	potential	competing	acquirer	that	
might	have	an	interest	in	acquiring	all	or	a	significant	part	
of	us	from	considering	or	proposing	that	acquisition	even	
if,	in	the	case	of	a	potential	acquisition	of	us,	it	were	
prepared	to	pay	consideration	with	a	higher	per	share	
price	to	our	shareholders	than	what	is	contemplated	in	
the	Proposed	TD	Merger,	or	might	result	in	a	potential	
competing	acquirer	proposing	to	pay	a	lower	per	share	
price	to	acquire	us	than	it	might	otherwise	have	proposed	
to	pay.

Shareholder	litigation	could	prevent	or	delay	the	
completion	of	the	Proposed	TD	Merger	or	otherwise	
negatively	impact	our	business	and	operations.	One	or	
more	of	our	shareholders	may	file	lawsuits	against	us	and/
or	our	directors	and	officers	in	connection	with	the	
Proposed	TD	Merger.	One	of	the	conditions	to	the	closing	
is	that	no	order,	injunction,	or	decree	issued	by	any	court	
or	governmental	entity	of	competent	jurisdiction	or	other	
legal	restraint	preventing	the	consummation	of	the	
Proposed	TD	Merger	or	any	of	the	other	transactions	
contemplated	by	the	TD	Merger	Agreement	and	related	
bank	merger	agreement	be	in	effect.	If	any	plaintiff	were	
successful	in	obtaining	an	injunction	prohibiting	us	from	
completing	the	Proposed	TD	Merger,	then	such	injunction	
may	delay	or	prevent	the	effectiveness	of	the	Proposed	TD	
Merger	and	could	result	in	significant	costs	to	us,	including	
any	cost	associated	with	the	indemnification	of	directors	
and	officers	of	each	company.	If	a	lawsuit	is	filed,	we	may	
incur	costs	in	connection	with	the	defense	or	settlement	
of	any	shareholder	lawsuits	filed	in	connection	with	the	
Proposed	TD	Merger.	Such	litigation	could	have	an	
adverse	effect	on	our	financial	condition	and	results	of	
operations	and	could	prevent	or	delay	the	completion	of	
the	Proposed	TD	Merger.

1A	beginning	on	page	35)	has	intensified	the	competitive	
environment.	

Some	competitors	are	traditional	banks,	subject	to	the	
same	regulatory	framework	as	we	are,	while	others	are	
not	banks	and	in	many	cases	experience	a	significantly	
different	or	reduced	degree	of	regulation.	Examples	of	
less-regulated	activities	include	check-cashing	services,	
independent	ATM	services,	and	“peer-to-peer”	lending,	
where	investors	provide	debt	financing	or	other	capital	
directly	to	borrowers.	

We	expect	that	competition	will	continue	to	grow	more	
intense	with	respect	to	most	of	our	products	and	
services.	Heightened	competition	tends	to	put	downward	
pressure	on	revenues	from	affected	items,	upward	
pressure	on	marketing	and	other	promotional	costs,	or	
both.	For	additional	information	regarding	competition	for	

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clients,	refer	to	Competition	within	Item	1	beginning	on	
page	16	of	this	report.

We	compete	for	talent.	Our	most	significant	competitors	
for	clients	also	tend	to	be	our	most	significant	competitors	
for	top	talent.	See	Operational	Risks	below	within	this	
Item	1A	for	additional	information	concerning	this	risk.

Traditional Strategic & Macro Risks

We	may	be	unable	to	successfully	implement	our	
strategy	to	operate	and	grow	our	regional	and	specialty	
banking	businesses.	Although	our	current	strategy	is	
expected	to	evolve	as	business	conditions	change,	in	2022	
our	primary	strategies	are	to	(1)	invest	resources	in	our	
banking	businesses	before	and	after	we	complete	the	
integration	of	the	businesses	and	operations	of	First	
Horizon	and	IBKC,	(2)	seek	to	exploit	opportunities	for	cost	
and	revenue	synergies,	(3)	seek	to	exploit	growth	
opportunities,	especially	within	the	markets	we	serve,	and	
(4)	seek	to	exploit	opportunities	to	cut	cost	without	
significant	revenue	impact.	Organic	growth,	including	
exploitation	of	revenue	synergies,	is	expected	to	be	
coordinated	with	a	focus	on	strong	and	stable	returns	on	
capital.	

Organically,	over	the	past	several	years	we	enhanced	our	
market	share	in	our	regional	banking	markets	with	
targeted	hires	and	marketing,	and	we	invested	resources	
in	specialty	commercial	lending	and	private	client	banking.	
After	the	completion	of	the	IBKC	merger	in	2020,	we	
started	to	invest	significantly	in	new	platforms	and	
processes	to	modernize	legacy	operations,	provide	a	
better	client	experience,	reduce	ongoing	operating	costs,	
and	support	future	growth	of	the	combined	franchise.	We	
expect	investments	of	that	sort	to	continue	in	2022.	
Investments	of	that	sort	are	expensive	in	the	near	term;	
although	we	believe	they	are	necessary	for	our	future	and	
are	appropriate	for	our	company	at	this	time,	the	financial	
returns	on	these	investments	are	highly	uncertain.

In	the	future	more	generally,	we	expect	to	continue	to	
nurture	profitable	organic	growth.	We	may	pursue	
acquisitions	or	strategic	transactions	if	appropriate	
opportunities,	within	or	outside	of	our	current	markets,	
present	themselves.	

The	TD	Merger	Agreement	restricts	us	from	making	
certain	acquisitions	and	taking	other	specified	actions	
while	the	Proposed	TD	Merger	is	pending	without	the	
consent	of	TD,	and	requires	us	to	operate	in	the	ordinary	
course	of	business.	These	restrictions	may	prevent	us	from	
pursuing	attractive	business	opportunities	that	may	arise	
prior	to	the	completion	of	the	Proposed	TD	Merger	or	may	
otherwise	adversely	affect	our	ongoing	business	and	
operations.	See	Risks	Related	to	the	Proposed	TD	Merger	
beginning	on	page	31	for	a	discussion	of	additional	risks	
related	to	the	Proposed	TD	Merger.

We	compete	to	raise	capital	in	the	equity	and	debt	
markets.	See	Liquidity	and	Funding	Risks	beginning	on	
page	46	of	this	Item	1A	for	additional	information	
concerning	this	risk.

.
Failure	to	achieve	one	or	more	key	elements	needed	for	
successful	organic	growth	would	adversely	affect	our	
business	and	earnings.	We	believe	that	the	successful	
execution	of	organic	growth	depends	upon	a	number	of	
key	elements,	including:

• our	ability	to	attract	and	retain	clients	in	our	banking	

market	areas;

• our	ability	to	achieve	and	maintain	growth	in	our	

earnings	while	pursuing	new	business	opportunities;

• our	ability	to	maintain	a	high	level	of	client	service	
while	optimizing	our	physical	banking	center	count	
due	to	changing	client	demand,	all	while	expanding	
our	remote	banking	services	and	expanding	or	
enhancing	our	information	processing,	technology,	
compliance,	and	other	operational	infrastructures	
effectively	and	efficiently;	

• our	ability	to	manage	the	liquidity	and	capital	

requirements	associated	with	growth,	especially	
organic	growth	and	cash-funded	acquisitions;	and

• our	ability	to	manage	effectively	and	efficiently	the	

changes	and	adaptations	necessitated	by	a	complex,	
burdensome,	and	evolving	regulatory	environment.

We	have	in	place	strategies	designed	to	achieve	those	
elements	that	are	significant	to	us	at	present.	Our	
challenge	is	to	execute	those	strategies	and	adjust	them,	
or	adopt	new	strategies,	as	conditions	change.

Failure	to	achieve	one	or	more	key	elements	needed	for	
successful	business	acquisitions	would	adversely	affect	
our	business	and	earnings.	In	relation	to	the	IBKC	merger	
and	the	30-branch	acquisition	that	we	closed	in	2020,	and	
to	the	extent	we	engage	in	future	bank	or	non-bank	
business	acquisitions,	we	face	various	additional	risks,	
including:

• our	ability	to	realize	planned	strategic	and	tactical	
objectives,	including	operating	efficiencies	and	
revenue	synergies,	within	a	reasonable	time	period	
after	closing	the	transaction;	

• our	ability	to	identify,	analyze,	and	correctly	assess	

the	execution,	credit,	contingency,	and	other	risks	in	
the	acquisition	and	to	price	the	transaction	
appropriately;

• our	ability	to	properly	evaluate	loss	inherent	in	the	

target	business’	loan	portfolios;

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• our	ability	to	integrate	the	acquired	business’	

operations,	clients,	and	properties	quickly	and	cost-
effectively;

• our	ability	to	manage	cultural	assimilation	risks	

associated	with	growth	through	acquisitions,	which	
can	be	an	often-overlooked	and	often-critical	failure	
point	in	mergers;	

• our	ability	to	combine	the	franchise	values	of	the	two	
companies	without	significant	loss	from	re-branding	
and	other	similar	changes;	and

• our	ability	to	retain	core	clients	and	key	associates.

These	risks	may	be	exacerbated	by	the	Proposed	TD	
Merger.	See	Risks	Related	to	the	Proposed	TD	Merger	
beginning	on	page	31	for	a	discussion	of	additional	risks	
related	to	the	Proposed	TD	Merger.

Industry Disruption

Through	technological	innovations	and	changes	in	client	
habits,	the	manner	in	which	clients	use	financial	services	
continues	to	change	at	a	rapid	pace.	We	provide	a	large	
number	of	services	remotely	(online	and	mobile),	and	
physical	banking	center	utilization	has	been	in	long-term	
decline	throughout	the	industry	for	many	years.	
Technology	has	helped	us	reduce	costs	and	improve	
service,	but	also	has	weakened	traditional	geographic	and	
relationship	ties,	and	has	allowed	disruptors	to	enter	
traditional	banking	areas.	

Through	digital	marketing	and	service	platforms,	many	
banks	are	making	client	inroads	unrelated	to	physical	
presence.	This	competitive	risk	is	especially	pronounced	
from	the	largest	U.S.	banks,	and	from	online-only	banks,	
due	in	part	to	the	investments	they	are	able	to	sustain	in	
their	digital	platforms.	

Companies	as	disparate	as	PayPal	(an	online	payment	
clearinghouse)	and	Starbucks	(a	large	chain	of	cafes)	
provide	payment	and	exchange	services	which	compete	
directly	with	banks	in	ways	not	possible	traditionally.	

The	nature	of	technology-driven	disruption	to	our	
industry	is	changing,	in	some	cases	seeking	to	displace	
traditional	financial	service	providers	rather	than	merely	
enhance	traditional	services	or	their	delivery.	A	number	
of	recent	technologies	have	worked	with	the	existing	
financial	system	and	traditional	banks,	such	as	the	
evolution	of	ATM	cards	into	debit/credit	cards	and	the	
evolution	of	debit/credit	cards	into	smart	phones.	These	
sorts	of	technologies	often	have	expanded	the	market	for	
banking	services	overall	while	siphoning	a	portion	of	the	
revenues	from	those	services	away	from	banks	and	
disrupting	prior	methods	of	delivering	those	services.	But	
some	recent	innovations	may	tend	to	replace	traditional	
banks	as	financial	service	providers	rather	than	merely	
augment	those	services.	

A	type	of	strategic	acquisition—a	so-called	“merger	of	
equals”	where	the	company	we	nominally	acquire	has	
similar	size,	operating	contribution,	or	value—presents	
unique	opportunities	but	also	unique	risks.	Those	special	
risks	include:

• the	potential	for	elevated	and	duplicative	operating	

expenses	if	we	are	unable	to	integrate	the	two	
companies	efficiently	in	a	reasonable	amount	of	time;	
and

• the	potential	for	a	significant	increase	in	the	time	
horizon	that	may	be	needed	before	substantial	
economies	of	scale	can	be	realized	or	substantial	
revenue	synergies	can	be	developed	effectively.

The	IBKC	merger	continued	to	present	these	special	risks	
in	2021	and	early	in	2022.	We	expect	them	to	diminish	as	
the	integration	processes	wind	down	this	year.	

For	example,	companies	which	claim	to	offer	applications	
and	services	based	on	artificial	intelligence	are	beginning	
to	compete	much	more	directly	with	traditional	financial	
services	companies	in	areas	involving	personal	advice,	
including	high-margin	services	such	as	financial	planning	
and	wealth	management.	The	low-cost,	high-speed	nature	
of	these	“robo-advisor”	services	can	be	especially	
attractive	to	younger,	less-affluent	clients	and	potential	
clients,	as	well	as	persons	interested	in	“self-service”	
investment	management.	Other	industry	changes,	such	as	
zero-commission	trading	offered	by	certain	large	firms	
able	to	use	trading	as	a	loss-leader,	may	amplify	this	
trend.

Similarly,	inventions	based	on	blockchain	technology	
eventually	may	be	the	foundation	for	greatly	enhancing	
transactional	security	throughout	the	banking	industry,	
but	also	eventually	may	decentralize	financial	services,	
reducing	the	demand	for	banks	as	secure	deposit-keepers	
and	financial	intermediaries.

We	believe	that,	over	the	course	of	the	technology-
driven	evolution	of	our	industry	which	is	well	underway,	
the	“winners”	will	be	those	institutions	which	can	know	
their	clients	and	make	those	clients	feel	they	are	known,	
even	when	many	clients	increasingly	do	not	visit	banking	
centers	or	have	face-to-face	live	interaction.	Two	keys	to	
achieving	a	psychological	connection	with	such	clients	are	
(1)	data	management	and	analytics,	using	artificial	
intelligence	processes,	which	allow	an	institution	to	
provide	a	differentiated,	personalized	experience	for	the	
client	at	the	point	of	interaction,	and	(2)	seamless	
integration	of	real-time	client	contact	with	a	human	being	
through	voice,	chat,	or	other	means.	

A	critical	factor	in	successful	data	analytics,	allowing	real-
time	differentiated	interaction	with	clients,	is	how	
traditionally	uncaptured,	unstructured,	or	siloed	data	is	

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acquired,	managed,	and	accessed.	While	many	banks	are	
attempting	to	address	this	business	need	in	various	ways,	
it	remains	unclear	which	approaches	will	be	successful	in	
the	long	run.	In	addition,	external	vendors	are	developing	
processes	to	provide	solutions.	A	basic	challenge	for	all	
these	efforts	is	how	to	integrate	analysis	of	extremely	
disparate	forms	of	data	and	utilize	that	analysis	in	each	
client	contact	in	a	manner	which	most	clients	not	only	
accept,	but	value.

Developing	workable	proprietary	solutions	to	the	data	
analytics	challenges	ahead	of	competitors	requires	
substantial	investment	in	information	technology	
systems	and	innovation.	Even	with	a	substantial	IT	
budget,	we	cannot	outspend,	or	even	come	close	to	
matching,	the	largest	U.S.	banking	institutions.	Therefore,	
like	most	U.S.	banks,	our	strategy	must	be	focused	on	
leveraging	products	and	solutions	which	are	within	our	
means,	including	those	developed	by	external	vendors.	
Our	goal	must	be	to	keep	pace	with	industry	
developments	with	a	focus	on	improving	the	client’s	
differentiated	experience	with	us	by	recognizing	and	
responding	to	client	needs.	

Technological	innovation	has	tended	to	reduce	barriers	to	
entry	based	on	cost.	Put	another	way,	once	someone	finds	
a	new,	better	method	to	accomplish	a	task	in	our	industry,	
often	others	are	able	to	replicate	or	improve	on	that	
method,	sometimes	quite	rapidly.	Key	risks	for	us,	
therefore,	are	whether	we	will	be	able:	to	catch	up	to	
breakthroughs	quickly	enough	to	avoid	client	attrition;	to	
adopt	and	enhance	breakthroughs	frequently	enough,	and	
without	significant	technical	failures,	to	attract	clients	
from	competitors;	and,	if	we	are	able	to	truly	innovate,	to	
press	our	advantage	quickly	before	competitors	adopt	it.

To	thrive	as	our	industry	is	disrupted,	we	will	need	to	
embrace	some	of	the	attitudes	of	a	technology	company,	
and	shed	some	of	the	traditional	attitudes	often	
associated	with	banking.	This	has	required,	and	will	
continue	to	require,	an	evolution	in	our	corporate	culture	
which,	in	turn,	creates	implementation	risk.	In	this	

Operational Risks

Fraud	is	a	major,	and	increasing,	operational	risk	for	us	
and	all	banks.	Two	traditional	areas,	deposit	fraud	(check	
kiting,	wire	fraud,	etc.)	and	loan	fraud,	continue	to	be	
major	sources	of	fraud	attempts	and	actual	loss.	The	
methods	used	to	perpetrate	and	combat	fraud	continue	to	
evolve	as	technology	changes.	In	addition	to	cybersecurity	
risk	(discussed	below),	new	technologies	have	made	it	
easier	for	bad	actors	to	obtain	and	use	client	personal	
information,	mimic	communications	and	signatures,	and	
otherwise	create	false	instructions	and	documents	that	
appear	genuine.

Our	anti-fraud	actions	are	both	preventive	(anticipating	
lines	of	attack,	educating	associates	and	clients,	etc.)	and	

evolutionary	process	it	is	critical	that	we	not	lose	sight	of	
how	our	clients	experience	working	with	us	and	our	
systems,	including	those	clients	who	still	want	
traditionally-delivered	services,	those	who	seek	and	
embrace	the	latest	innovations,	and	those	who	just	want	
services	to	be	convenient,	personalized,	and	
understandable.

Just	as	disruptive	business	changes	driven	by	new	
technologies	and	new	client	preferences	can	adversely	
impact	us	and	our	entire	industry,	similar	events	can	
adversely	impact	our	commercial	clients.	In	time,	a	major	
business	disruption	can	cause	dominant	businesses	to	fail,	
and	can	shrink	or	even	end	entire	lines	of	business.	An	
example	of	this	is	the	business	failure	of	the	Blockbuster	
video	distribution	chain	and	most	other	video	distribution	
stores,	and	the	rise	of	Netflix	and	similar	services.	Many	
other	examples	of	this	kind	of	process	are	ongoing	today	
in	many	industries,	including	publishing,	retail	sales,	news,	
and	the	creation	as	well	as	distribution	of	audio	and	video	
entertainment.	To	the	extent	disruptions	impact	our	
clients,	we	may	experience	elevated	loan	losses	and	loss	
of	ongoing	business	which	we	may	not	be	able	to	
recapture	with	new	clients.

As	an	illustration,	the	COVID-19	pandemic	drove	
substantial	changes	in	the	preferences	and	practices	of	
customers	of	many	industries,	including	those	of	many	of	
our	clients.	In	some	cases	the	changes	in	customer	
behaviors	may	be	temporary,	and	in	others	the	changes	
may	be	more	permanent.	For	example,	we	have	a	
significant	franchise	finance	business,	largely	involving	the	
restaurant	industry.	Those	clients	of	ours	which,	before	
the	pandemic,	had	robust	mobile	app,	drive-through,	and	
home	delivery	channels	weathered	the	pandemic	much	
better,	on	average,	than	others	in	that	industry.	Although	
traditional	dine-in	demand	should	increase	once	the	
pandemic	is	no	longer	a	major	public	concern,	it	is	not	
certain	when	or	whether	that	demand	will	return	to	pre-
pandemic	levels.	

responsive	(detecting,	halting,	and	remediating	actual	
attacks).	Our	regulators	require	us	to	report	fraud	
promptly,	and	regulators	often	advise	banks	of	new	
schemes	so	that	the	entire	industry	can	adapt	as	quickly	as	
possible.	However,	some	level	of	fraud	loss	is	unavoidable,	
and	the	risk	of	a	major	loss	cannot	be	eliminated.

Our	ability	to	conduct	and	grow	our	businesses	is	
dependent	in	part	upon	our	ability	to	create,	maintain,	
expand,	and	evolve	an	appropriate	operational	and	
organizational	infrastructure,	manage	expenses,	and	
recruit	and	retain	personnel	with	the	ability	to	manage	a	
complex	business.	Operational	risk	can	arise	in	many	
ways,	including:		errors	related	to	failed	or	inadequate	

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physical,	operational,	information	technology,	or	other	
processes;	faulty	or	disabled	computer	or	other	
technology	systems;	fraud,	theft,	physical	security	
breaches,	electronic	data	and	related	security	breaches,	or	
other	criminal	conduct	by	associates	or	third	parties;	and	
exposure	to	other	external	events.	Inadequacies	may	
present	themselves	in	myriad	ways.	Actions	taken	to	
manage	one	risk	may	be	ineffective	against	others.	For	
example,	information	technology	systems	may	be	
insufficiently	redundant	to	withstand	a	fire,	incursion,	
malware,	or	other	major	casualty,	and	they	may	be	
insufficiently	adaptable	to	new	business	conditions	or	
opportunities.	Efforts	to	make	systems	more	robust	may	
make	them	less	adaptable,	and	vice-versa.	Also,	our	
efforts	to	control	expenses,	which	is	a	significant	priority	
for	us,	increases	our	operational	challenges	as	we	strive	to	
maintain	client	service	and	compliance	at	high	quality	and	
low	cost.	

An	information	technology	security	(cybersecurity)	
breach	or	other	incident	can	cause	significant	damage,	
and	can	be	difficult	to	detect	even	after	it	occurs.	Among	
other	things,	that	damage	can	occur	due	to	outright	theft,	
loss	or	extortion	of	our	funds	or	our	clients’	funds,	fraud	
or	identity	theft	perpetrated	on	clients,	loss	of	confidential	
or	proprietary	information,	business	disruption,	or	
adverse	publicity	associated	with	a	breach	or	incident	and	
its	potential	effects.	Perpetrators	potentially	can	be	
associates,	clients,	and	certain	vendors,	all	of	whom	
legitimately	have	access	to	some	portion	of	our	systems,	
as	well	as	outsiders	with	no	legitimate	access.

Cybersecurity	incidents	happen	frequently;	they	are	an	
unavoidable	part	of	doing	business.	Often,	but	not	
always,	we	detect	and	block	the	attempt.	Often,	but	not	
always,	the	number	of	clients	impacted	is	modest	and	our	
loss	is	minimal	or	none.	Even	with	significant	loss	
prevention	and	mitigation	systems,	the	risk	of	a	financially	
or	reputationally	significant	incursion	cannot	be	
eliminated.	Common	categories	of	cybersecurity	incidents	
relevant	to	us,	as	a	bank,	include:	account	takeover,	client	
spoofing,	and	payment	fraud;	ransomware	and	other	
malware;	client	interface	attacks	(attempts	to	shut	down	
or	slow	down	our	website	or	mobile	app);	and	cloud	
(remote	server)	incursions.	Common	vulnerabilities	
include:	clients	and	associates	that	fall	victim	to	malicious	
emails	or	other	communications	and	inappropriately	share	
credentials	allowing	access	to	accounts	or	systems;	older	
software	or	systems	that	do	not	have	up-to-date	security	
and	are	not	sufficiently	isolated	from	other	systems;	third-
party	software	vulnerabilities;	and	third-party	systems	
vulnerabilities.	We	believe	the	bad	actors	have	a	range	of	
motivations,	including:	illegal	profit;	politically	or	
geopolitically	motivated	disruption;	and	vandalism.	Bad	
actors	can	range	from	amateurs	to	criminal	organizations	
to	nation-states.

Because	of	the	potential	for	very	serious	consequences	
associated	with	these	risks,	our	electronic	systems	and	

their	upgrades	need	to	address	internal	and	external	
security	concerns	to	a	high	degree,	and	our	systems	must	
comply	with	applicable	banking	and	other	regulations	
pertaining	to	bank	safety	and	client	protection.	Although	
many	of	our	defenses	are	systemic	and	highly	technical,	
others	are	much	older	and	more	basic.	For	example,	
periodically	we	train	all	our	associates	to	recognize	red	
flags	associated	with	fraud,	theft,	and	other	electronic	
crimes,	and	we	educate	our	clients	as	well	through	regular	
and	episodic	security-oriented	communications.	We	
expect	our	systems	and	regulatory	requirements	to	
continue	to	evolve	as	technology	and	criminal	techniques	
also	continue	to	evolve.

The	operational	functions	we	outsource	to	third	parties	
may	experience	similar	disruptions	that	could	adversely	
impact	us	and	over	which	we	may	have	limited	control	
and,	in	some	cases,	limited	ability	to	obtain	an	alternate	
vendor	quickly.	To	the	extent	we	rely	on	third	party	
vendors	to	perform	or	assist	operational	functions,	the	
challenge	of	managing	the	associated	risks	may	become	
more	difficult.	We	manage	this	risk	by	assessing	the	
adequacy	of	cybersecurity	prevention	and	detection	
systems	and	programs	of	critical	vendors.	

The	operational	functions	of	business	counterparties,	or	
businesses	with	which	we	have	no	relationship,	may	
experience	disruptions	that	could	adversely	impact	us	
and	over	which	we	may	have	limited	or	no	control.	
Although	these	events	cannot	be	predicted	individually,	
over	time	and	in	the	aggregate	they	happen	as	surely	as	
loan	losses.	For	example,	when	a	major	U.S.	consumer-
oriented	firm	experiences	a	data	systems	incursion	
resulting	in	the	theft	of	credit	and	debit	card	information,	
online	account	information,	and	other	data,	it	impacts	
thousands	or	sometimes	millions	of	people.	Frequently,	
many	of	those	affected	are	our	clients.	Although	our	
systems	are	not	breached	by	third-party	incursions,	these	
events	can	increase	account	fraud	and	can	cause	us	to	
take	costly	steps	to	avoid	significant	theft	loss	to	our	Bank	
and	our	clients.	Our	ability	to	recoup	our	losses	may	be	
limited	legally	or	practically	in	many	situations.	Possible	
points	of	incursion	or	disruption	not	within	our	control	
include	retailers,	utilities,	insurers,	health	care	service	
providers,	internet	service	and	electronic	mail	providers,	
social	media	portals,	distant-server	(“cloud”)	service	
providers,	electronic	data	security	providers,	
telecommunications	companies,	and	smart	phone	
manufacturers.

Failure	to	build	and	maintain,	or	outsource,	the	
necessary	operational	infrastructure,	failure	of	that	
infrastructure	to	perform	its	functions,	or	failure	of	our	
disaster	preparedness	plans	if	primary	infrastructure	
components	suffer	damage,	can	lead	to	risk	of	loss	of	
service	to	clients,	legal	actions,	and	noncompliance	with	
applicable	regulatory	standards.	Additional	information	
concerning	operational	risks	and	our	management	of	
them,	all	of	which	is	incorporated	into	this	Item	1A	by	this	

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Table	of	Contents

ITEM	1A.	RISK	FACTORS

reference,	appears	under	the	caption	Operational	Risk	
Management	beginning	on	page	94	of	our	2021	MD&A	
(Item	7).

unable	to	use	these	tools	effectively,	we	face	the	risk	that,	
over	time,	our	best	talent	will	leave	us	and	we	will	be	
unable	to	replace	those	persons	effectively.

The	delivery	of	financial	services	to	clients	and	others	
increasingly	depends	upon	technologies,	systems,	and	
multi-party	infrastructures	which	are	new,	creating	or	
enhancing	several	risks	discussed	elsewhere.	Examples	of	
the	risks	created	or	enhanced	by	the	widespread	and	
rapid	adoption	of	relatively	untested	technologies	include:	
security	incursions;	operational	malfunctions	or	other	
disruptions;	and	legal	claims	of	patent	or	other	intellectual	
property	infringement.

Competition	for	talent	is	substantial	and	increasing.	
Moreover,	revenue	growth	in	some	business	lines	
increasingly	depends	upon	top	talent.	In	recent	years	the	
cost	to	us	of	hiring	and	retaining	top	revenue-producing	
talent	has	increased,	and	that	trend	is	likely	to	continue.	
The	primary	tools	we	use	to	attract	and	retain	talent	are:		
salaries;	commission,	incentive,	and	retention	
compensation	programs;	retirement	benefits;	change	in	
control	severance	benefits;	health	and	other	welfare	
benefits;	and	our	corporate	culture.	To	the	extent	we	are	
.

Incentives	might	operate	poorly	or	have	unintended	
adverse	effects.	Incentive	programs	are	difficult	to	design	
well,	and	even	if	well-designed	often	they	must	be	
updated	to	address	changes	in	our	business.	A	poorly	
designed	incentive	program—where	goals	are	too	
difficult,	too	easy,	or	not	well	related	to	desired	outcomes
—could	provide	little	useful	motivation	to	key	associates,	
could	increase	turnover,	and	could	impact	client	
retention.	Moreover,	even	where	those	pitfalls	are	
avoided,	incentive	programs	may	create	unintended	
adverse	consequences.	For	example,	a	program	focused	
entirely	on	revenue	production,	without	proper	controls,	
may	result	in	costs	growing	faster	than	revenues.

We	face	the	risk	that	our	competitors	may	seek	to	use	
the	Proposed	TD	Merger	to	target	our	clients.	See	Risks	
Related	to	the	Proposed	TD	Merger	beginning	on	page	31	
for	a	discussion	of	additional	risks	related	to	the	Proposed	
TD	Merger.

Risks from Economic Downturns & Changes

Generally,	in	an	economic	downturn,	our	realized	credit	
losses	increase,	demand	for	our	products	and	services	
declines,	and	the	credit	quality	of	our	loan	portfolio	
declines.	Delinquencies	and	realized	credit	losses	
generally	increase	during	economic	downturns	due	to	an	
increase	in	liquidity	problems	for	clients	and	downward	
pressure	on	collateral	values.	Likewise,	demand	for	loans	
(at	a	given	level	of	creditworthiness),	deposit	and	other	
products,	and	financial	services	may	decline	during	an	
economic	downturn,	and	may	be	adversely	affected	by	
other	national,	regional,	or	local	economic	factors	that	
impact	demand	for	loans	and	other	financial	products	and	
services.	Such	factors	include,	for	example,	changes	in	
employment	rates,	interest	rates,	real	estate	prices,	or	
expectations	concerning	rates	or	prices.	Accordingly,	an	

economic	downturn	or	other	adverse	economic	change	
(local,	regional,	national,	or	global)	can	hurt	our	financial	
performance	in	the	form	of	higher	loan	losses,	lower	loan	
production	levels,	lower	deposit	levels,	compression	of	
our	net	interest	margin,	and	lower	fees	from	transactions	
and	services.	Those	effects	can	continue	for	many	years	
after	the	downturn	technically	ends.

Because	all	banks	are	sensitive	to	the	risk	of	downturns,	
the	stock	prices	of	all	banks	typically	decline,	sometimes	
substantially,	if	the	market	believes	that	a	downturn	has	
become	more	likely	or	is	imminent.	This	effect	can	and	
often	does	occur	indiscriminately,	initially	without	much	
regard	to	different	risk	postures	of	different	banks.

Risks Associated with Monetary Events

The	Federal	Reserve	has	implemented	significant	
economic	strategies	that	have	impacted	interest	rates,	
inflation,	asset	values,	and	the	shape	of	the	yield	curve.	
These	strategies	have	had,	and	will	continue	to	have,	a	
significant	impact	on	our	business	and	on	many	of	our	
clients.	To	illustrate:	in	response	to	the	recession	in	2008	
and	the	following	uneven	recovery,	the	Federal	Reserve	
implemented	a	series	of	domestic	monetary	initiatives	
designed	to	lower	rates	and	make	credit	easier	to	obtain.	
The	Federal	Reserve	changed	course	in	2015,	raising	rates	
several	times	through	2018.	The	last	raise	in	2018	was	
accompanied	by	a	substantial	and	broad	stock	market	

decline.	In	2019	the	Federal	Reserve	began	to	lower	rates.	
In	2020,	in	response	to	economic	disruption	associated	
with	the	COVID-19	pandemic,	the	Federal	Reserve	quickly	
reduced	short-term	rates	to	extremely	low	levels	and	
acted	to	influence	the	markets	to	reduce	long-term	rates	
as	well.	During	2021,	the	Federal	Reserve	significantly	
reduced	its	"easing"	actions	that	held	down	long-term	
rates.	For	2022,	the	Federal	Reserve	has	indicated	that	it	
expects	to	end	all	easing	and	to	begin	raising	short-term	
rates,	subject	in	all	events	to	changes	in	economic	data.	

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Table	of	Contents

Normalizing	(raising)	interest	rates	in	2022,	and	possibly	
later,	is	likely	to	have	several	significant	impacts	on	our	
businesses	even	if	(as	expected)	rates	remain	low	by	
historical	norms.	Key	among	those:	(1)	income	from	loans	
should	increase,	but	so	should	our	cost	of	deposits,	and	
the	levels	or	timing	of	those	two	increases	may	be	uneven	
or	unsynchronized	so	that	our	net	interest	margin	could	
become	less	predictable	during	the	transition	period;	(2)	a	
key	negative	feature	of	the	past	low-rate	environment	has	
been	a	flatter	than	normal	yield	curve,	and	although	it	is	
possible	rising	rates	will	steepen	the	curve,	it	is	also	
possible	that	the	yield	curve	will	flatten	(see	the	next	
paragraph)	or	fluctuate	unpredictably	during	the	
transition	period;	(3)	higher	rates,	rising	rates,	and	a	
flatter	yield	curve	each	tend	to	adversely	impact	our	fixed	
income	revenues;	and	(4)	higher	rates	tend	to	adversely	
impact	three	mortgage-related	businesses,	consisting	of	
origination,	title	services,	and	lending	to	mortgage	
companies,	and	changes	in	those	businesses	can	be	
significant	and	sudden	in	reaction	to	changes	in	mortgage	
rates.	

Recent	statements	by	the	Federal	Reserve	indicate	an	
expectation	to	reduce	its	asset	holdings	in	2022,	which	will	
put	upward	pressure	on	long-term	interest	rates.	We	
believe	these	statements	were	driven	by	a	concern	that,	
as	short	and	long	rates	rise,	short	rates	will	rise	faster,	
resulting	in	a	flatter	yield	curve.	Reducing	the	Federal	
Reserve's	asset	holdings	would	be	intended	to	blunt	that	
flattening.	

The	discussion	above	is	qualified	by	several	key	unknowns:	
(1)	although	the	Federal	Reserve	can	directly	change	
extremely	short-term	interest	rates,	its	ability	to	affect	
long-term	rates	is	indirect	and	tempered	by	market	forces	
it	cannot	control;	(2)	we	do	not	know	what	the	Federal	
Reserve	actually	will	do	since	all	statements	of	possible	or	
expected	future	actions	are	subject	to	future	economic	
events	and	data;	(3)	the	U.S.	economy	is	in	a	transitional	
period,	and	economic	events	and	data	have	frequently	
defied	prediction	over	the	past	few	quarters;	and	(4)	even	
if	overall	events	and	trends	follow	current	expectations,	
interest	rates	and	the	yield	curve	could	experience	periods	
of	volatility	as	short-term	economic	imbalances	work	
themselves	out	in	the	markets.

Additional	information	concerning	these	monetary	policy	
transition	risks	is	presented:	under	the	caption	Cyclicality	
within	the	Other	Business	Information	section	of	Item	1,	
which	starts	on	page	18;	within	the	Effect	of	
Governmental	Policies	and	Proposals	section	of	Item	1	
beginning	on	page	29;	in	Interest	Rate	and	Yield	Curve	
Risks	beginning	on	page	48;	and	under	the	caption	Federal	
Reserve	Policy	in	Transition	within	the	Market	

Uncertainties	and	Prospective	Trends	section	of	our	2021	
MD&A	(Item	7),	beginning	on	page	99.

Federal	Reserve	strategies	can,	and	often	are	intended	
to,	affect	the	domestic	money	supply,	inflation,	interest	
rates,	and	the	shape	of	the	yield	curve.	Effects	on	the	
yield	curve	often	are	most	pronounced	at	the	short	end	of	
the	curve,	which	is	of	particular	importance	to	us	and	
other	banks.	Among	other	things,	easing	strategies	are	
intended	to	lower	interest	rates,	flatten	the	yield	curve,	
expand	the	money	supply,	and	stimulate	economic	
activity,	while	tightening	strategies	are	intended	to	
increase	interest	rates,	steepen	the	yield	curve,	tighten	
the	money	supply,	and	restrain	economic	activity.	

Many	external	factors	may	interfere	with	the	effects	of	
these	plans	or	cause	them	to	be	changed,	sometimes	
quickly.	Such	factors	include	significant	economic	trends	
or	events	as	well	as	significant	international	monetary	
policies	and	events.	Such	strategies	also	can	affect	the	U.S.	
and	world-wide	financial	systems	in	ways	that	may	be	
difficult	to	predict.	Risks	associated	with	interest	rates	and	
the	yield	curve	are	discussed	in	this	Item	1A	under	the	
caption	Interest	Rate	and	Yield	Curve	Risks	beginning	on	
page	48.

We	may	be	adversely	affected	by	economic	and	political	
situations	outside	the	U.S.	The	U.S.	economy,	and	the	
businesses	of	many	of	our	clients,	are	linked	significantly	
to	economic	and	market	conditions	outside	the	U.S.,	
especially	in	North	and	Central	America,	Europe,	and	Asia,	
and	increasingly	in	South	America.	Although	our	direct	
exposure	to	non-US-dollar-denominated	assets	or	non-US	
sovereign	debt	is	insignificant,	in	the	future	major	adverse	
events	outside	the	U.S.	could	have	a	substantial	indirect	
adverse	impact	upon	us.	Key	potential	events	which	could	
have	such	an	impact	include	(1)	sovereign	debt	default	
(default	by	one	or	more	governments	in	their	borrowings),	
(2)	bank	and/or	corporate	debt	default,	(3)	market	and	
other	liquidity	disruptions,	and,	if	stresses	become	
especially	severe,	(4)	the	collapse	of	governments,	
alliances,	or	currencies,	and	(5)	military	conflicts.	The	
methods	by	which	such	events	could	adversely	affect	us	
are	highly	varied	but	broadly	include	the	following:		an	
increase	in	our	cost	of	borrowed	funds	or,	in	a	worst	case,	
the	unavailability	of	borrowed	funds	through	conventional	
markets;	impacts	upon	our	hedging	and	other	
counterparties;	impacts	upon	our	clients;	impacts	upon	
the	U.S.	economy,	especially	in	the	areas	of	employment	
rates,	real	estate	values,	interest	rates,	and	inflation/
deflation	rates;	and	impacts	upon	us	from	our	regulatory	
environment,	which	can	change	substantially	and	
unpredictably	from	possible	political	response	to	major	
financial	disruptions.

Risks Related to Businesses We May Exit

We	may	be	unable	to	successfully	implement	a	
disposition	or	wind-down	of	businesses	or	units	which	no	

longer	fit	our	strategic	plans.	We	consider	possible	
closures	and	divestitures	as	we	continue	to	adapt	to	a	

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Table	of	Contents

changing	business	and	regulatory	environment.	Actions	of	
this	sort	typically	are	elevated	in	the	first	few	years	after	a	
significant	merger.	Following	our	2017	merger	with	Capital	
Bank	Financial,	we	closed/consolidated	several	banking	
locations	and	we	sold	a	few	of	the	smaller	operating	
businesses	that	did	not	fit	well	with	our	strategic	outlook.	
In	2021	we	closed/consolidated	several	dozen	banking	
locations	in	the	wake	of	the	2020	IBKC	merger,	and	other	
exiting	actions	may	follow.	Key	risks	associated	with	
exiting	a	business	include:

• our	ability	to	price	a	sale	transaction	appropriately	

and	otherwise	negotiate	acceptable	terms;

• our	ability	to	identify	and	implement	key	client,	

personnel,	technology	systems,	and	other	transition	

Reputation Risks

Our	ability	to	conduct	and	grow	our	businesses,	and	to	
obtain	and	retain	clients,	is	highly	dependent	upon	
external	perceptions	of	our	business	practices	and	
financial	stability.	Our	reputation	is,	therefore,	a	key	asset	
for	us.	Our	reputation	is	affected	principally	by	our	
business	practices	and	how	those	practices	are	perceived	
and	understood	by	others.	Adverse	perceptions	regarding	
the	practices	of	our	competitors,	or	our	industry	as	a	
whole,	also	may	adversely	impact	our	reputation.	In	
addition,	negative	perceptions	relating	to	parties	with	
whom	we	have	important	relationships	may	adversely	
impact	our	reputation.	Senior	management	oversees	
processes	for	reputation	risk	monitoring,	assessment,	and	
management.

Damage	to	our	reputation	could	hinder	our	ability	to	
access	the	capital	markets	or	otherwise	impact	our	
liquidity,	could	hamper	our	ability	to	attract	new	clients	
and	retain	existing	ones,	could	impact	the	market	value	of	
our	stock,	could	create	or	aggravate	regulatory	difficulties,	
and	could	undermine	our	ability	to	attract	and	retain	
talented	associates,	among	other	things.	Adverse	impacts	
on	our	reputation,	or	the	reputation	of	our	industry,	also	
may	result	in	greater	regulatory	and/or	legislative	
scrutiny,	which	may	lead	to	laws	or	regulations	that	
change	or	constrain	our	business	or	operations.	Events	
that	result	in	damage	to	our	reputation	also	may	increase	
our	litigation	risk.

Credit Risks

actions	to	avoid	or	minimize	negative	effects	on	
retained	businesses;	

• our	ability	to	mitigate	the	loss	of	any	pretax	income	

that	the	exited	business	produced;

• our	ability	to	assess	and	manage	any	loss	of	synergies	

that	the	exited	business	had	with	our	retained	
businesses;	and

• our	ability	to	manage	capital,	liquidity,	and	other	
challenges	that	may	arise	if	an	exit	results	in	
significant	legacy	cash	expenditures	or	financial	loss.

Political	and	social	fragmentation	in	the	U.S.,	combined	
with	access	to	social	media	platforms,	can	increase	
reputation	risk	in	ways	that	might	not	be	easily	avoided	
by	traditional	means.	The	predominant	culture	within	the	
banking	industry	remains	traditional:	in	order	to	preserve	
their	business	reputations,	banks	generally	prefer	to	avoid	
direct,	public	involvement	in	political	or	social	
controversy.	Increasingly,	though,	certain	groups—having	
highly	specific	political	or	social	agendas	and	with	the	
ability	to	communicate	their	views	effectively	using	social	
media	platforms—have	made	it	more	difficult	to	maintain	
a	traditional	approach.	One	group,	for	example,	may	
publicly	criticize	a	bank	for	having,	as	a	client,	a	business	
which	“exploits”	persons	of	limited	financial	means,	while	
another	group	may	criticize	a	bank	for	failing	to	have,	as	a	
client,	the	same	business	which	“serves”	such	persons	in	
neighborhoods	that	many	businesses	avoid.	As	another	
example,	a	group	may	demand	that	a	bank	cease	doing	
business	with	a	specific	business	client	based	on	the	
client’s	industry	or	a	specific	business	practice	because	
that	industry	or	practice,	though	legal,	is	objectionable	to	
that	group.	While	the	potential	for	such	demands	has	
always	existed,	special	interest	groups	today	are	more	
able	and	willing	to	publicize	their	criticisms,	and	some	are	
willing	to	use	factual	exaggerations	and	inflammatory	
language	in	stating	their	views	to	the	public.	Those	
criticisms,	in	turn,	ultimately	may	be	acted	upon	by	
legislators	or	regulators.

We	face	the	risk	that	our	clients	may	not	repay	their	
loans	and	that	the	realizable	value	of	collateral	may	be	
insufficient	to	avoid	a	charge-off.	We	also	face	risks	that	
other	counterparties,	in	a	wide	range	of	situations,	may	
fail	to	honor	their	obligations	to	pay	us.	In	our	business	
some	level	of	credit	charge-offs	is	unavoidable	and	overall	
levels	of	credit	charge-offs	can	vary	substantially	over	
time.	In	the	last	pre-COVID	credit	cycle,	net	charge-offs	

were	$132	million	in	2007,	and	increased	to	$573	million	
and	$832	million	in	2008	and	2009,	respectively.	Beginning	
in	2010,	net	charge-offs	began	to	decline,	reaching	$13	
million	by	2017	and	remaining	historically	very	low	
through	2019.	In	2020,	net	charge-offs	unexpectedly	rose	
to	$120	million,	driven	strongly	by	the	COVID-induced	
recession	starting	in	March.	Net	charge-offs	in	2021	fell	
sharply	to	$2	million,	a	very	low	level	historically.	We	

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believe	this	favorable	outcome	was	substantially	affected	
by	our	client	selection	and	underwriting	processes,	along	
with	our	willingness	to	work	with	borrowers	throughout	
the	pandemic.	We	do	not	think	it	likely	that	net	charge-
offs	in	the	future	will	remain	at	2021's	low	level.			

Our	ability	to	manage	credit	risks	depends	primarily	upon	
our	ability	to	assess	the	creditworthiness	of	loan	clients	
and	other	counterparties	and	the	value	of	any	collateral,	
including	real	estate,	among	other	things.	We	further	
manage	credit	risk	by	diversifying	our	loan	portfolio,	by	
managing	its	granularity,	by	following	per-relationship	
lending	limits,	and	by	recording	and	managing	an	
allowance	for	loan	and	lease	losses	based	on	the	factors	
mentioned	above	and	in	accordance	with	applicable	
accounting	rules.	We	further	manage	other	counterparty	
credit	risk	in	a	variety	of	ways,	some	of	which	are	
discussed	in	other	parts	of	this	Item	1A	and	all	of	which	
have	as	a	primary	goal	the	avoidance	of	having	too	much	
risk	concentrated	with	any	single	counterparty.

We	record	loan	charge-offs	in	accordance	with	accounting	
and	regulatory	guidelines	and	rules.	As	indicated	in	this	
Item	1A	under	the	caption	Accounting	&	Tax	Risks	
beginning	on	page	51,	these	guidelines	and	rules	could	
change	and	cause	provision	expense	or	charge-offs	to	be	
more	volatile,	or	to	be	recognized	on	an	accelerated	basis,	
for	reasons	not	always	related	to	the	underlying	
performance	of	our	portfolio.	In	fact,	starting	in	2020,	
such	an	accounting	change	was	made	and,	when	the	
COVID	recession	occurred	starting	in	March,	provision	for	
credit	losses	significantly	increased.	Moreover,	the	SEC	or	
PCAOB	could	take	accounting	positions	applicable	to	our	
holding	company	that	may	be	inconsistent	with	those	
taken	by	the	Federal	Reserve	or	other	banking	regulators.	

A	significant	challenge	for	us	is	to	keep	the	credit	and	
other	models	and	approaches	we	use	to	originate	and	
manage	loans	updated	to	take	into	account	changes	in	the	
competitive	environment,	in	real	estate	prices	and	other	
collateral	values,	in	the	economy,	and	in	the	regulatory	
environment,	among	other	things,	based	on	our	
experience	originating	loans	and	servicing	loan	portfolios.	
Changes	in	modeling	could	have	significant	impacts	upon	
our	reported	financial	results	and	condition.	In	addition,	
we	use	those	models	and	approaches	to	manage	our	loan	
portfolios	and	lending	businesses.	To	the	extent	our	
models	and	approaches	are	not	consistent	with	underlying	
real-world	conditions,	our	management	decisions	could	be	
misguided	or	otherwise	affected	with	substantial	adverse	
consequences	to	us.	A	recent	and	still-current	example	of	
challenges	we	face	in	modeling	stems	from	the	COVID-19	
pandemic	and	its	related	impacts	on	clients,	the	economy,	
and	governmental	interventions	and	accommodations.

The	recent	low-interest	rate	environment	has	elevated	
the	traditional	challenge	for	lenders	and	investors	to	
balance	taking	on	higher	risk	against	the	desire	for	higher	
income	or	yield.	This	challenge	applies	not	only	to	credit	

risk	in	lending	activities	but	also	to	default	and	rate	risks	
regarding	investments.

When	interest	rates	eventually	rise,	default	risk	likely	
also	will	rise.	As	borrowers’	obligations	to	pay	interest	
increase,	financial	weaknesses	generally	become	more	
evident.	Initially	this	results	in	lower	consumer	credit	
scores	and	lower	commercial	loan	grading,	and	later	
results	in	higher	default	rates.	

Realized	credit	losses	tend	to	increase	and	decrease	in	a	
cyclical	manner,	although	the	duration	and	timing	of	any	
given	credit	cycle	is	impossible	to	predict	accurately.	
Through	2019	we	and	other	U.S.	banks	experienced	an	
extended	period	of	very	low	credit	losses.	

The	credit	cycle	was	disrupted	by	COVID-19.	Our	
expectation	for	loan	losses	in	2020	rose	sharply	with	the	
COVID-19	pandemic	and	its	recession,	though	in	many	
cases	actual	losses,	reflected	in	net	charge	offs,	did	not	
later	materialize.	Our	expectations	for	credit	loss	abated	
dramatically	in	2021,	and	significant	amounts	of	the	2020	
loss	reserves	were	released,	resulting	in	provision	credits	
(negative	expenses).	We	do	not	know	what	the	new	
“normal”	level	of	provision	for	credit	loss	will	be	once	the	
impacts	of	the	pandemic	have	fully	ended,	or	what	long-
term	impact	the	pandemic	will	have	on	the	credit	cycle.	
The	low	provision	and	net	charge-off	levels	experienced	
before	2020	were	historically	unusual	and	might	not	be	
repeated.	It	is	extremely	difficult	for	banks,	and	for	
investors,	to	know	when	an	uptick	in	credit	loss	is	merely	
idiosyncratic	or	instead	portends	a	major	credit	cycle	
change.

Based	on	the	foregoing	discussions,	we	expect	loan	loss	
provision	expense	and	net	charge-offs	to	be	higher	than	
2021	during	the	next	several	years.	We	hope	to	offset	
that	headwind	with	loan	growth	and,	if	interest	rates	rise	
and	the	yield	curve	steepens,	higher	margins.	Loan	growth	
in	2022	will	be	blunted	by	run-off	of	pandemic-era	short-
term	lending	under	special	government	programs,	and	
may	be	blunted	if	rates	rise	too	much	or	too	quickly.	

The	composition	of	our	loans	inherently	increases	our	
sensitivity	to	certain	credit	risks.	At	December	31,	2021,	
approximately	57%	of	total	loans	and	leases	consisted	of	
the	commercial,	financial,	and	industrial	(C&I)	portfolio,	
while	approximately	20%	consisted	of	the	consumer	real	
estate	portfolio.	

The	largest	component	of	the	C&I	portfolio	at	year	end	
was	loans	to	mortgage	companies,	a	component	which	
represented	about	15%	of	the	C&I	portfolio	at	that	time.	
The	second	largest	component	was	loans	to	finance	and	
insurance	companies.	As	a	result,	approximately	26%	of	
the	C&I	portfolio	was	sensitive	to	impacts	on	the	financial	
services	industry.	As	discussed	elsewhere	in	this	Item	1A	
with	respect	to	our	company,	the	financial	services	
industry	is	more	sensitive	to	interest	rate	and	yield	curve	
changes,	monetary	policy,	regulatory	policy,	changes	in	

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real	estate	and	other	asset	values,	and	changes	in	general	
economic	conditions,	than	many	other	industries.	
Negative	impacts	on	the	industry	could	dampen	new	
lending	in	these	lines	of	business	and	could	create	credit	
impacts	for	the	loans	in	our	portfolio.

The	consumer	real	estate	portfolio	contains	a	number	of	
concentrations	which	affect	credit	risk	assessment	of	the	
portfolio.

• Product	concentration.	The	consumer	real	estate	

portfolio	consists	primarily	of	consumer	installment	
loans,	and	much	of	the	remainder	consists	of	home	
equity	lines	of	credit.	

• Collateral	concentration.	This	entire	category	is	

secured	by	residential	real	estate.	Approximately	14%	
of	the	consumer	real	estate	portfolio	consists	of	loans	
secured	on	a	second-lien	basis.	

• Geographic	concentration.	At	year	end,	about	65%	of	
the	consumer	real	estate	portfolio	related	to	clients	in	
three	states:	Florida,	Tennessee,	and	Louisiana.	

The	consumer	real	estate	category	is	highly	sensitive	to	
economic	impacts	on	consumer	clients	and	on	residential	
real	estate	values.	Job	loss	or	downward	job	migration,	as	
well	as	significant	life	events	such	as	divorce,	death,	or	
disability,	can	significantly	impact	credit	evaluations	of	the	

Service Risks

We	provide	a	wide	range	of	services	to	clients,	and	the	
provision	of	these	services	may	create	claims	against	us	
that	we	provided	them	in	a	manner	that	harmed	the	
client	or	a	third	party,	or	was	not	compliant	with	
applicable	laws	or	rules.	Our	services	include	lending,	
loan	servicing,	fiduciary,	custodial,	depositary,	funds	
management,	insurance,	and	advisory	services,	among	
others.	We	manage	these	risks	primarily	through	training	

portfolio.	Also,	regulatory	changes,	discussed	above	and	
elsewhere	in	this	Item	1A,	are	more	likely	to	affect	the	
consumer	category	and	our	accounting	estimates	of	credit	
loss	than	other	loan	types.

Volatility	in	the	oil	and	gas	industry	can	impact	us.	At	
year-end,	approximately	2%	of	our	total	loans	were	
directly	related	to	the	oil	and	gas	industry.	In	addition	to	
general	credit	and	other	risks	mentioned	elsewhere	in	this	
Item	1A,	these	businesses	and	their	related	assets	are	
sensitive	to	a	number	of	factors	specific	to	that	industry.	
Key	among	those	is	global	demand	for	energy	and	other	
products	from	oil	and	gas	in	relation	to	supply.	The	
shifting	balance	between	demand	and	supply	is	expressed	
most	simply	in	prices.	Significant	oil-price	volatility,	such	
as	that	experienced	in	2020-2021,	can	and	often	does	
impact	our	overall	business	in	this	industry	by	increasing	
provisioning	and	charge-offs,	and	by	reducing	demand	for	
loans.	Another	set	of	risks	specific	to	that	industry	relate	
to	environmental	concerns,	including	the	risks	of	
increased	regulation	or	other	governmental	intervention,	
and	the	risks	of	adverse	changes	in	consumption	habits	or	
public	perceptions	generally.		

Additional	information	concerning	credit	risks	and	our	
management	of	them	is	set	forth	under	the	caption	Asset	
Quality	beginning	on	page	73	of	our	2021	MD&A	(Item	7).

programs,	compliance	programs,	and	supervision	
processes.	Additional	information	concerning	these	risks	
and	our	management	of	them,	all	of	which	is	incorporated	
into	this	Item	1A	by	this	reference,	appears	under	the	
captions	Operational	Risk	Management	and	Compliance	
Risk	Management,	beginning	on	page	94	of	our	2021	
MD&A	(Item	7).

Risks Related to COVID-19 Pandemic

The	COVID-19	pandemic	has	led	to	periods	of	significant	
volatility	in	financial,	commodities	(including	oil	and	gas)	
and	other	markets,	has	adversely	affected	our	ability	to	
conduct	normal	business,	has	adversely	affected	our	
clients,	continues	to	adversely	impact	U.S.	and	global	
manufacturing	and	delivery	processes,	and	is	likely	to	
continue	to	harm	our	businesses	and	results	of	
operations	in	ways	that	are	difficult	to	predict.

Starting	in	late	February	2020,	financial	market	volatility	
increased	dramatically	based	on	concerns	that	COVID-19,	
and	the	steps	being	undertaken	in	many	countries	to	
mitigate	its	spread,	would	significantly	disrupt	economic	
activity.	In	March	2020,	financial	market	volatility	
increased	further,	with	several	one-day	stock	market	
swings	that	resulted	in	significant	market	declines.	
Additionally:	market	pricing	deteriorated	in	virtually	all	

sectors	and	asset	classes	except	U.S.	Treasury	securities;	
many	states	and	cities	in	the	U.S.	declared	health	
emergencies,	lockdowns,	travel	restrictions,	and	
quarantines,	prohibiting	gatherings	of	more	than	a	small	
number	of	people	and	ordering	or	urging	most	businesses	
and	workplaces	to	close	or	operate	on	a	very	restricted	
basis;	the	Federal	Reserve	lowered	short-term	interest	
rates	and	started	a	“quantitative	easing”	program	
intended	to	lower	longer-term	interest	rates	and	foster	
access	to	credit;	the	effective	yields	of	10-year	and	30-
year	U.S.	Treasury	securities	achieved	record	low	rates;	
and	the	U.S.	Congress	enacted	several	relief	laws.	
Government	actions	in	the	U.S.	have	included	loan	
programs	administered	by	banks	and	other	private-sector	
lenders,	liquidity	programs	administered	by	the	U.S.	
Treasury,	and	favorable	accounting	and	regulatory	
treatment	(for	lenders)	of	certain	loan	payment	deferrals.

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In	2020,	the	economic	effects	of	these	and	related	actions	
and	events	in	the	U.S.	included:	large	numbers	of	partial	
or	full	business	closures;	large	numbers	of	people	were	
furloughed	or	laid	off;	large	increases	in	unemployment;	
large	numbers	of	workers	worked	from	home;	and	large	
numbers	of	consumers	were	unwilling	to	undertake	
significant	discretionary	spending.	In	addition,	worldwide	
demand	for	oil	fell,	resulting	in	significant	drops	in	oil	
prices	and	in	the	values	of	oil-related	assets.	

Starting	in	late	2020,	and	accelerating	in	2021,	vaccines	
were	distributed	throughout	the	U.S.	and	the	physical	and	
commercial	shutdowns	started	to	abate.	Late	in	2021,	
monoclonal	antibody	treatments	and	new	anti-viral	
medications	offered	hope	that	infected	people	could	
avoid	the	worst	outcomes	of	the	virus	more	effectively	
than	with	earlier	treatments.	Additional	strains	of	
COVID-19	have	emerged	worldwide,	a	few	of	which	have	
caused	some	earlier	restrictions	to	reappear	but	without	
the	very	large	economic	shocks	experienced	in	2020.	It	
appears	likely	that	further	new	strains	will	continue	to	
appear,	as	they	do	with	influenza.	It	also	appears	likely	
that	a	"return	to	normal"	in	2022	or	2023	will	be	uneven	
and	delayed	at	best,	and	that	"normal"	behavior	patterns	
in	the	U.S.	may	become	somewhat	different	than	they	
were	pre-COVID.	

Within	the	U.S.,	governmental	reactions	to	the	pandemic	
in	2021	have	been,	and	in	2022	very	likely	will	continue	to	
be,	inconsistent	from	state	to	state	and	from	city	to	city.	
Worldwide,	these	inconsistencies	have	been	more	
pronounced,	including	enforced	quarantine	of	large	
population	segments	if	any	outbreak	is	detected	in	some	
countries,	closed	borders	in	some	countries,	and	virtually	
no	restrictions	at	all	in	some	countries.	This	situation,	
coupled	with	unpredictable	work	slowdowns	associated	
with	illness	outbreaks,	likely	has	contributed	significantly	
to	global	supply	chain	and	related	difficulties	that	were	
commonplace	in	2021.

We	are	not	able	to	predict	the	impact	of	these	still-
changing	circumstances	on	our	businesses.	The	full	extent	
of	impacts	resulting	from	the	COVID-19	pandemic	and	
other	events	beyond	our	control	will	depend	on	uncertain	
future	developments,	including	new	information	which	
may	emerge	concerning	the	severity	of	new	COVID	strains,	
the	effectiveness	of	vaccines	and	treatments	on	existing	
and	new	strains,	and	further	actions	governments	may	
take	to	slow	the	spread	of	the	virus,	treat	the	ill,	distribute	

the	vaccines	and	treatments,	and	assist	affected	
businesses.	

In	addition,	the	pandemic	has	resulted	in	modest	
operational	disruptions	for	us.	Clients’	physical	access	to	
banking	centers	has	been	restricted	off	and	on	in	many	
markets,	and	many	non-client-facing	associates	continued	
to	work	largely	on	a	remote	basis	into	early	2022.	In	
addition,	associates	have	become	ill	unpredictably,	which	
occasionally	slowed	or	modestly	disrupted	certain	
functions	or	processes.		More	significant	disruptions	in	the	
future	could	adversely	impact	our	businesses,	financial	
condition,	and	results	of	operations.		

Changes	in	interest	rates	due	to	Federal	Reserve	actions	
and	market	forces,	mentioned	above,	negatively	
impacted	our	net	interest	margin	(a	measure	of	the	
average	profit	margin	applicable	to	lending).	The	Federal	
Reserve	has	indicated	its	expectations	to	end	easing,	and	
begin	raising	short-term	interest	rates,	in	2022,	but	the	
timing	and	degree	of	normalization	cannot	be	predicted.	
Additional	information	is	presented:	under	the	caption	
Cyclicality	within	the	Other	Business	Information	section	of	
Item	1,	which	starts	on	page	18;	Risks	Associated	with	
Monetary	Events	beginning	on	page	38;	in	Interest	Rate	
and	Yield	Curve	Risks	beginning	on	page	48;	and	under	the	
caption	Federal	Reserve	Policy	in	Transition	within	the	
Market	Uncertainties	and	Prospective	Trends	section	of	
our	2021	MD&A	(Item	7),	beginning	on	page	99.	

Our	clients	and	vendors	have	been	adversely	impacted	
by	governmental	and	societal	responses	to	COVID-19.	
Those	impacts	on	clients	reduced	noninterest	income,	
created	downward	loan	migration	(a	reduction	in	loan-
grading),	and	substantially	increased	provision	for	credit	
losses	in	2020.	Another	sudden	adverse	change	in	
circumstances	could	result	in	another	round	of	
unexpected	provision	expense	along	with	a	reduction	of	
noninterest	income.

In	2022,	certain	commercial	loans	will	run	off,	and	a	
portion	of	certain	deposit	accounts	may	diminish.	In	2020	
and	2021,	in	response	to	the	pandemic,	the	U.S.	
guaranteed	a	category	of	commercial	loans	under	the	
paycheck	protection	program	("PPP"),	and	further	created	
rounds	of	direct-to-citizen	cash	payment	programs.	At	
December	31,	2021,	we	had	$1	billion	of	PPP	loans	
outstanding,	nearly	all	of	which	we	expect	to	be	paid	in	
2022.

Regulatory, Legislative, & Legal Risks

The	regulatory	environment	continues	to	be	challenging.	
We	operate	in	a	heavily	regulated	industry.	Our	regulatory	
burdens,	including	both	operating	restrictions	and	ongoing	
compliance	costs,	are	substantial.	

We	are	subject	to	many	banking,	deposit,	insurance,	
securities	brokerage	and	underwriting,	investment	

management,	and	consumer	lending	regulations	in	
addition	to	the	rules	applicable	to	all	companies	publicly	
traded	in	the	U.S.	securities	markets	and,	in	particular,	on	
the	New	York	Stock	Exchange.	Failure	to	comply	with	
applicable	regulations	could	result	in	financial,	structural,	
and	operational	penalties.	In	addition,	efforts	to	comply	
with	applicable	regulations	may	increase	our	costs	and/or	

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limit	our	ability	to	pursue	certain	business	opportunities.	
See	Supervision	and	Regulation	within	Item	1	of	this	
report,	beginning	on	page	21,	for	additional	information	
concerning	financial	industry	regulations.	Federal	and	
state	regulations	significantly	limit	the	types	of	activities	in	
which	we,	as	a	financial	institution,	may	engage.	In	
addition,	we	are	subject	to	a	wide	array	of	other	
regulations	that	govern	other	aspects	of	how	we	conduct	
our	business,	such	as	in	the	areas	of	employment	and	
intellectual	property.	Federal	and	state	legislative	and	
regulatory	authorities	increasingly	consider	changing	
these	regulations	or	adopting	new	ones.	Such	actions	
could	further	limit	the	amount	of	interest	or	fees	we	can	
charge,	could	further	restrict	our	ability	to	collect	loans	or	
realize	on	collateral,	could	affect	the	terms	or	profitability	
of	the	products	and	services	we	offer,	or	could	materially	
affect	us	in	other	ways.	

The	following	paragraphs	highlight	certain	specific	
important	risk	areas	related	to	regulatory	matters	
currently.	These	paragraphs	do	not	describe	these	risks	
exhaustively,	and	they	do	not	describe	all	such	risks	that	
we	face	currently.	Moreover,	the	importance	of	specific	
risks	will	grow	or	diminish	as	circumstances	change.

We	and	our	Bank	both	are	required	to	maintain	certain	
regulatory	capital	levels	and	ratios.	U.S.	capital	standards	
are	discussed	in	Item	1	of	this	report,	in	tabular	and	
narrative	form,	under	the	caption	Capital	Adequacy	within	
the	Supervision	&	Regulation	section	of	Item	1	which	
starts	on	page	21.	Pressures	to	maintain	appropriate	
capital	levels	and	address	business	needs	in	a	changing	
economy	may	lead	to	actions	that	could	be	dilutive	or	
otherwise	adverse	to	our	shareholders.	Such	actions	could	
include:		reduction	or	elimination	of	dividends;	the	
issuance	of	common	or	preferred	stock,	or	securities	
convertible	into	stock;	or	the	issuance	of	any	class	of	stock	
having	rights	that	are	adverse	to	those	of	the	holders	of	
our	existing	classes	of	common	or	preferred	stock.

Additional	information	concerning	these	risks	and	our	
management	of	them,	all	of	which	is	incorporated	into	
this	Item	1A	by	this	reference,	appears:	under	the	captions	
Capital	Adequacy	and	Prompt	Corrective	Action	(PCA)	
within	the	Supervision	&	Regulation	section	of	Item	1	
which	starts	on	page	21;	under	the	captions	Capital,	
Capital	Risk	Management	and	Adequacy,	and	Market	
Uncertainties	and	Prospective	Trends	beginning	on	pages	
87,	94,	and	99,	respectively,	of	our	2021	MD&A	(Item);	
and	under	the	caption	Regulatory	Capital	in	Note	13—
Regulatory	Capital	and	Restrictions,	beginning	on	page	
159	of	our	2021	Financial	Statements	(Item	8).

Regulation	of	banks	is	tiered	based	on	asset	size;	we	are	
close	to	reaching	$100	billion,	which	is	the	next	tier	
above	us.	Regulatory	restrictions	and	costs	tend	to	
increase	based	on	asset	tier.	The	two	most	significant	
impacts	on	us	of	crossing	the	$100	billion	threshold	are:	
becoming	subject	to	Category	IV	enhanced	prudential	

standards;	and	becoming	at-risk	for	being	subject	to	a	
liquidity	coverage	ratio	requirement.	Additional	
information	appears	in	the	Supervision	&	Regulation	
section	of	Item	1	which	starts	on	page	21.	To	reach	the	
next	tier	will	require	only	modest	organic	growth	for	
another	two	or	three	years,	and	even	a	modest	bank	
acquisition	is	likely	to	put	us	over	$100	billion.

Legal	disputes	are	an	unavoidable	part	of	business,	and	
the	outcome	of	pending	or	threatened	litigation	cannot	
be	predicted	with	any	certainty.	We	face	the	risk	of	
litigation	from	clients,	associates,	vendors,	contractual	
parties,	and	other	persons,	either	singly	or	in	class	actions,	
and	from	federal	or	state	regulators.	Matters	of	that	sort	
are	pending	currently;	it	is	unlikely	we	will	ever	experience	
a	time	when	no	litigation	matter	is	outstanding.	We	
manage	litigation	risks	through	internal	controls,	
personnel	training,	insurance,	litigation	management,	our	
compliance	and	ethics	processes,	and	other	means.	
However,	the	commencement,	outcome,	and	magnitude	
of	litigation	cannot	be	predicted	or	controlled	with	any	
certainty.

Typically,	we	are	unable	to	estimate	our	loss	exposure	
from	legal	claims	until	relatively	late	in	the	litigation	
process,	which	can	make	our	financial	recognition	of	loss	
from	litigation	unpredictable	and	highly	uneven	from	
one	period	to	the	next.	For	most	of	our	pending	legal	
matters	we	have	established	either	no	accrual	(reserve)	or	
no	significant	reserve.	Financial	accounting	guidance	
requires	that	litigation	loss	be	both	estimable	and	
probable	before	a	reserve	may	be	established	(recorded	
as	a	liability	on	our	balance	sheet).	Under	that	guidance,	
reserves	typically	are	not	established	for	most	litigation	
matters	until	after	preliminary	motions	to	dismiss	or	to	
narrow	the	case	are	resolved,	after	discovery	is	
substantially	in	process,	and	(in	many	cases)	after	
preliminary	overtures	regarding	settlement	have	
occurred.	Potentially	significant	cases	often	are	pending	
for	years	before	any	loss	is	recognized	and	a	reserve	is	
established.	Moreover,	many	cases	experience	relatively	
little	progress	toward	resolution	for	a	long	period	followed	
by	a	brief	period	of	rapid	development.	Lastly,	although	
most	cases	are	resolved	with	little	or	no	loss	to	us,	for	the	
others	our	loss	typically	is	recognized	either	all	at	once	
(near	the	time	of	resolution)	or	very	unevenly	over	the	life	
of	the	case.	

Additional	information	concerning	litigation	risks	and	our	
management	of	them,	all	of	which	is	incorporated	into	
this	Item	1A	by	this	reference,	appears:	under	the	caption	
Pre-2009	Mortgage	Business	Risks	beginning	on	page	51;	
under	the	captions	Repurchase	Obligations,	Market	
Uncertainties	and	Prospective	Trends,	and	Contingent	
Liabilities	beginning	on	pages	98,	99,	and	103,	
respectively,	of	our	2021	MD&A	(Item	7);	and	under	the	
caption	Contingencies	in	Note	17—Contingencies	and	
Other	Disclosures,	beginning	on	page	168	of	our	2021	
Financial	Statements	(Item	8).

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Political	dysfunction	and	volatility	within	the	federal	
government,	both	at	the	regulatory	and	Congressional	
level,	creates	significant	potential	for	major	and	abrupt	
shifts	in	federal	policy	regarding	bank	regulation,	taxes,	
and	the	economy,	any	of	which	could	have	significant	
impacts	on	our	business	and	financial	performance.	
Moreover,	political	conflict	within	and	among	branches	of	
government,	and	within	and	among	government	agencies,	
can	rise	to	a	level	where	day-to-day	functions	could	be	
interrupted	or	impaired.

Data	privacy	is	becoming	a	major	political	concern.	The	
laws	governing	it	are	new,	and	are	likely	to	evolve	and	
expand.	Many	non-regulated,	non-banking	companies	
have	gathered	large	amounts	of	personal	details	about	
millions	of	people,	and	have	the	ability	to	analyze	that	
data	and	act	on	that	analysis	very	quickly.	This	situation	
has	prompted	governmental	responses.	Two	prominent	
responses	are	the	European	Union	General	Data	
Protection	Regulation	and	the	California	Consumer	Privacy	
Act.	Neither	is	a	banking	industry	regulation,	but	both	
apply	to	banks	in	relation	to	certain	clients.	Further	
general	regulation	to	protect	data	privacy	appears	likely.	
Banks	in	the	U.S.	already	operate	under	privacy-protection	
laws	and	rules,	but	banking	industry	regulations	in	this	
area	might	be	enlarged	in	response	to	this	concern.

Public	expectations	concerning	corporate	controls	on	
emissions	of	carbon	dioxide,	methane,	and	other	

Risks of Expense Control

Our	ability	to	successfully	manage	expenses	is	important	
to	our	long-term	success,	but	in	part	is	subject	to	risks	
beyond	our	control.	Many	factors	can	influence	the	
amount	of	our	expenses,	as	well	as	how	quickly	they	grow.	
As	our	businesses	change—whether	by	acquisition,	
expansion,	or	contraction—additional	expenses	can	arise	
from	asset	purchases,	structural	reorganization,	evolving	
business	strategies,	and	changing	regulations,	among	
other	things.	

We	manage	controllable	expenses	and	risk	through	a	
variety	of	means,	including	selectively	outsourcing	or	
multi-sourcing	various	functions	and	procurement	
coordination	and	processes.	In	recent	years	we	have	
actively	sought	to	make	strategic	businesses	more	
efficient	primarily	by	investing	in	technology,	re-thinking	
and	right-sizing	our	physical	facilities,	and	re-thinking	and	
right-sizing	our	workforce	and	incentive	programs.	These	
efforts	usually	entail	additional	near-term	expenses	in	the	
form	of	technology	purchases	and	implementation,	facility	
closure	or	renovation	costs,	and	severance	costs,	while	
expected	benefits	typically	are	realized	with	some	
uncertainty	in	the	future.	

greenhouse	gases	could	increase	our	operating	costs	in	
the	future	without	a	corresponding	increase	in	revenue,	
could	curtail	some	aspects	of	our	business,	or	both.	At	
present,	environmental	regulations	do	not	require	us	to	
monitor	the	direct	or	indirect	greenhouse	gas	emissions	
associated	with	building,	operating,	or	maintaining	our	
physical	facilities,	nor	are	we	taxed	or	fined	in	relation	to	
those	emissions,	because	such	gases	generally	are	not	
considered	to	be	pollutants	under	federal	law.	Changing	
expectations	could	pressure	us	to	physically	measure,	
monitor,	and	curtail	direct	emissions	and	to	estimate	
indirect	emissions	or	impacts,	and	eventually	could	result	
in	legal	requirements	to	take	those	actions	or	to	pay	for	
measured	or	estimated	emissions.	Whether	or	not	legally	
required,	any	such	actions	that	we	take	would	increase	
our	operating	costs.	In	addition,	such	expectations	could	
pressure	us	to	discontinue	business	relationships	with	
certain	clients,	or	groups	of	clients,	that	have	suboptimal	
reputations	for	emissions.

Although	currently	no	proposal	has	been	published,	
future	regulations	could	discourage	us	from	lending	to	
clients	in	certain	industries	judged	to	be	environmentally	
high-risk,	even	if	those	elevated	risk	factors	have	a	long	
time	horizon	or	are	speculative	for	other	reasons.	
Changes	of	that	sort	could	curtail	our	ability	to	pursue	
profitable	business	opportunities.

We	have	also	focused	on	the	economic	profit	generated	
by	our	business	activities	and	prospects	rather	than	
emphasizing	revenues	or	ordinary	profit.	Economic	profit	
analysis	attempts	to	relate	ordinary	profit	to	the	capital	
employed	to	create	that	profit	with	the	goal	of	achieving	
higher	(more	efficient)	returns	on	capital	employed	
overall.	Activities	with	higher	capital	usage	bear	a	greater	
burden	in	economic	profit	analysis.	The	process	is	
intended	to	allow	us	to	more	efficiently	manage	
investment	and	utilization	of	resources.	Economic	profit	
analysis	involves	significant	judgment	regarding	capital	
allocation.	Mistakes	in	those	judgments	could	result	in	a	
mis-allocation	of	resources	and	diminished	profitability	
over	the	long	run.

Despite	our	efforts,	our	costs	could	rise	due	to	adverse	
structural	changes	or	market	shifts.	For	example:	in	2021	
and	early	2022,	compensation	costs	have	risen	markedly	
due	to	market	forces	beyond	our	control;	and	the	overall	
cost	of	our	health	insurance	benefit	is	highly	dependent	
upon	regulatory	factors	and	market	forces	which	also	are	
beyond	our	control.

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Geographic Risks

We	are	subject	to	risks	of	operating	in	various	
jurisdictions.	To	a	significant	degree	our	banking	business	
is	exposed	to	economic,	regulatory,	natural	disaster,	and	
other	risks	that	primarily	impact	the	south-eastern	and	
south-central	U.S.	states	where	we	do	most	of	our	
regional	banking	business.	If	those	regions	of	the	U.S.	
were	to	experience	adversity	not	shared	by	other	parts	of	
the	country,	we	are	likely	to	experience	adversity	to	a	
degree	not	shared	by	those	competitors	which	have	a	
broader	or	different	regional	footprint.	Examples	of	these	
kinds	of	risks	include:	earthquakes	in	Memphis;	hurricanes	
in	Florida,	Louisiana,	the	Carolina	coasts,	or	the	Texas	
coast;	a	major	change	in	health	insurance	laws	impacting	
the	many	healthcare	companies	in	middle	Tennessee;	and	
automotive	industry	plant	closures.

We	have	international	assets,	mainly	in	the	form	of	loans	
and	letters	of	credit.		Holding	non-U.S.	assets	creates	a	

Insurance

Our	property	and	casualty	insurance	may	not	cover	or	
may	be	inadequate	to	cover	the	risks	that	we	face,	and	
we	are	or	may	be	adversely	affected	by	a	default	by	
insurers.	We	use	insurance	to	manage	a	number	of	risks,	
including	damage	or	destruction	of	property	as	well	as	
legal	and	other	liability.	Not	all	such	risks	are	insured,	in	
any	given	insured	situation	our	insurance	may	be	
inadequate	to	cover	all	loss,	and	many	risks	we	face	are	
uninsurable.	For	those	risks	that	are	insured,	we	also	face	
the	risks	that	the	insurer	may	default	on	its	obligations	or	
that	the	insurer	may	refuse	to	honor	them.	We	treat	the	
risk	of	default	as	a	type	of	credit	risk,	which	we	manage	by	
reviewing	the	insurers	that	we	use	and	by	striving	to	use	
more	than	one	insurer	when	practical.	The	risk	of	refusal,	
whether	due	to	honest	disagreement	or	bad	faith,	is	
inherent	in	any	contractual	situation.

A	portion	of	our	consumer	loan	portfolio	involves	
mortgage	default	insurance.	If	a	default	insurer	were	to	
experience	a	significant	credit	downgrade	or	were	to	
become	insolvent,	that	could	adversely	affect	the	carrying	
value	of	loans	insured	by	that	company,	which	could	result	
in	an	immediate	increase	in	our	loan	loss	provision	or	
write-down	of	the	carrying	value	of	those	loans	on	our	
balance	sheet	and,	in	either	case,	a	corresponding	impact	
on	our	financial	results.	If	many	default	insurers	were	to	
experience	downgrades	or	insolvency	at	the	same	time,	
the	risk	of	a	financial	impact	would	be	amplified.

Liquidity & Funding Risks

number	of	risks:		the	risk	that	taxes,	fees,	prohibitions,	
and	other	barriers	and	constraints	may	be	created	or	
increased	by	the	U.S.	or	other	countries	that	would	impact	
our	holdings;	the	risk	that	currency	exchange	rates	could	
move	unfavorably	so	as	to	diminish	the	U.S.	dollar	value	of	
assets,	or	to	enlarge	the	U.S.	dollar	value	of	liabilities;	and	
the	risk	that	legal	recourse	against	foreign	counterparties	
may	be	limited	in	unexpected	ways.	Our	ability	to	manage	
those	and	other	risks	depends	upon	a	number	of	factors,	
including:	our	ability	to	recognize	and	anticipate	
differences	in	legal,	cultural,	and	other	expectations	
applicable	to	clients,	regulators,	vendors,	and	other	
business	partners	and	counterparties;	and	our	ability	to	
recognize	and	manage	any	exchange	rate	risks	to	which	
we	are	exposed.

We	own	certain	bank-owned	life	insurance	policies	as	
assets	on	our	balance	sheet.	Some	of	those	policies	are	
“general	account”	and	others	are	“separate	account.”	The	
general	account	policies	are	subject	to	the	risk	that	the	
carrier	might	experience	a	significant	downgrade	or	
become	insolvent.	The	separate	account	policies	are	less	
susceptible	to	carrier	risk,	but	do	carry	a	higher	risk	of	
value	fluctuations	in	securities	which	underlie	those	
policies.	Both	risks	are	managed	through	periodic	reviews	
of	the	carriers	and	the	underlying	security	values.	
However,	particularly	for	the	general	account	policies,	our	
ability	to	liquidate	a	policy	in	anticipation	of	an	adverse	
carrier	event	is	significantly	limited	by	applicable	
insurance	contracts	and	regulations	as	well	as	by	a	
substantial	tax	penalty	which	could	be	levied	upon	early	
policy	termination.

When	we	self-insure	certain	exposures,	our	estimates	of	
future	expenditures	may	be	inadequate	for	the	actual	
expenditures	that	occur.	For	example,	we	self-insure	our	
associate	health-insurance	benefit	program.	We	estimate	
future	expenditures	and	establish	accruals	(reserves)	
based	on	the	estimates.	If	actual	expenditures	were	to	
exceed	our	estimates	in	a	future	period,	our	future	
expenses	could	be	adversely	and	unexpectedly	increased.

Liquidity	is	essential	to	our	business	model	and	a	lack	of	
liquidity,	or	an	increase	in	the	cost	of	liquidity,	may	
materially	and	adversely	affect	our	businesses,	results	of	

operations,	financial	conditions	and	cash	flows.	In	
general,	the	costs	of	our	funding	directly	impact	our	costs	
of	doing	business	and,	therefore,	can	positively	or	

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negatively	affect	our	financial	results.	Our	funding	
requirements	in	2021	were	met	principally	by	deposits,	by	
financing	from	other	financial	institutions,	and	by	funds	
obtained	from	the	capital	markets.	

Deposits	traditionally	have	provided	our	most	affordable	
funds	and	by	far	the	largest	portion	of	funding.	However,	
deposit	trends	can	shift	with	economic	conditions.	If	
interest	rates	fall,	deposit	levels	in	our	Bank	might	fall,	
perhaps	fairly	quickly	if	a	tipping	point	is	reached,	as	
depositors	become	more	comfortable	with	risk	and	seek	
higher	returns	in	other	vehicles.	This	could	pressure	us	to	
raise	interest	we	pay	on	our	deposits,	which	could	shrink	
our	net	interest	margin	if	loan	rates	do	not	rise	
correspondingly.	

In	the	past	three	years,	interest	rates	paid	on	deposits	
have	fallen	to	remarkably	low	levels,	and	stock	market	
values	(broadly	speaking)	have	climbed.	Contrary	to	the	
expectations	outlined	in	the	paragraph	above,	deposit	
levels	also	have	climbed.	While	difficult	to	explain	
definitively,	it	is	possible	that	while	a	sizable	portion	of	
available	capital	holders	are	comfortable	with	risk	in	the	
stock	markets,	another	sizable	portion	are	highly	risk-
averse	in	light	of	the	severe	volatility	experienced	by	the	
stock	markets	in	2018,	2019,	and	2020.	Deposit	levels	in	
2020	and	2021	also	were	buoyed	by	Federal	pandemic	
assistance,	particularly	direct	cash	payments	to	most	
citizens.

Deposit	levels	may	be	affected,	fairly	quickly,	by	changes	
in	monetary	policy.	The	Federal	Reserve	currently	is	
changing	monetary	policy	from	easing	to	tightening.	The	
Federal	Reserve	has	indicated	it	intends	to	end	easing,	and	
begin	tightening,	based	on	economic	events	during	the	
year,	including	inflationary	pressures,	employment	data,	
and	overall	economic	activity.	Easing	thus	far	has	involved	
reducing	the	growth	rate	of	the	Federal	Reserve's	balance	
sheet	(bond	purchases),	eventually	to	zero.	If	the	Federal	
Reserve	decides	to	shrink	its	balance	sheet	in	order	to	
quickly	remove	excess	liquidity	from	the	banking	system,	
long-term	interest	rates	may	increase	suddenly,	and	
deposit	levels	may	decrease	significantly	as	clients	move	
funds	into	bonds	and	similar	instruments.	Additional	
information	concerning	monetary	policy	changes	appears	
under	the	caption	Risks	Associated	with	Monetary	Events	
beginning	on	page	38	within	this	Item	1A,	and	under	the	
caption	Federal	Reserve	Policy	in	Transition	within	the	
Market	Uncertainties	and	Prospective	Trends	section	of	
2021	MD&A	(Item	7),	which	begins	on	page	99.

The	market	among	banks	for	deposits	may	be	impacted	
by	capital	rules.	Those	rules	generally	provide	favorable	

Credit Ratings

treatment	for	core	deposits.	Institutions	with	less	than	
$100	billion	of	assets	are	not	required	to	maintain	a	
minimum	Liquidity	Coverage	ratio.	At	or	above	$100	
billion,	the	requirement	increases	with	size	and	certain	
activities.	The	largest	banks,	which	must	maintain	the	
highest	minimum	ratio,	may	be	incented	to	compete	for	
core	deposits	vigorously.	Although	mid-sized	banks,	like	
ours,	are	only	lightly	impacted	by	this	rule,	if	some	large	
banks	in	our	markets	take	aggressive	actions	we	could	lose	
deposit	share	or	be	compelled	to	adjust	our	deposit	
pricing	and	practices	in	ways	that	could	increase	our	costs.

We	also	depend	upon	financing	from	private	institutional	
or	other	investors	by	means	of	the	capital	markets.	In	
2020	we	issued	and	sold	$150	million	of	preferred	stock,	
along	with	a	total	of	$1.3	billion	of	senior	and	
subordinated	notes.	In	2021,	we	issued	and	sold	another	
$150	million	of	preferred	stock.	Presently	we	believe	we	
could	access	the	capital	markets	again	if	we	desired	to	do	
so.	Risk	remains,	however,	that	capital	markets	may	
become	unavailable	to	us	for	reasons	beyond	our	control.

A	number	of	more	general	factors	could	make	funding	
more	difficult,	more	expensive,	or	unavailable	on	
affordable	terms.	These	include,	but	not	limited	to,	our	
financial	results,	organizational	or	political	changes,	
adverse	impacts	on	our	reputation,	changes	in	the	
activities	of	our	business	partners,	disruptions	in	the	
capital	markets,	specific	events	that	adversely	impact	the	
financial	services	industry,	counterparty	availability,	
changes	affecting	our	loan	portfolio	or	other	assets,	
changes	affecting	our	corporate	and	regulatory	structure,	
interest	rate	fluctuations,	ratings	agency	actions,	general	
economic	conditions,	and	the	legal,	regulatory,	
accounting,	and	tax	environments	governing	our	funding	
transactions.	In	addition,	our	ability	to	raise	funds	is	
strongly	affected	by	the	general	state	of	the	U.S.	and	
world	economies	and	financial	markets	as	well	as	the	
policies	and	capabilities	of	the	U.S.	government	and	its	
agencies,	and	may	remain	or	become	increasingly	difficult	
due	to	economic	and	other	factors	beyond	our	control.	
Changes	associated	with	LIBOR	also	may	impact	our	
funding	ability;	see	Interest	Rate	and	Yield	Curve	Risks	
beginning	on	page	48.

Events	affecting	interest	rates,	markets,	and	other	
factors	may	adversely	affect	the	demand	for	our	
products	and	services	in	our	fixed	income	business.	As	a	
result,	disruptions	in	those	areas	may	adversely	impact	
our	earnings	in	that	business	unit.

Our	credit	ratings	directly	affect	the	availability	and	cost	
of	our	unsecured	funding.	Our	holding	company	(the	
Corporation)	and	our	Bank	currently	receive	ratings	from	
several	rating	agencies	for	unsecured	borrowings.	A	rating	

below	investment	grade	typically	reduces	availability	and	
increases	the	cost	of	market-based	funding.	A	debt	rating	
of	Baa3	or	higher	by	Moody’s	Investors	Service,	or	BBB-	or	
higher	by	Fitch	Ratings,	is	considered	investment	grade	for	

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many	purposes.	At	December	31,	2021,	both	rating	
agencies	rated	the	unsecured	senior	debt	of	the	
Corporation	and	of	the	Bank	as	investment	grade.	The	
ratings	outlook	was	stable	from	Moody’s	and	from	Fitch	
for	both	the	Corporation	and	the	Bank.	To	the	extent	that	
in	the	future	we	depend	on	institutional	borrowing	and	
the	capital	markets	for	funding	and	capital,	we	could	
experience	reduced	liquidity	and	increased	cost	of	
unsecured	funding	if	our	debt	ratings	were	lowered	
further,	particularly	if	lowered	below	investment	grade.	In	
addition,	other	actions	by	ratings	agencies	can	create	
uncertainty	about	our	ratings	in	the	future	and	thus	can	
adversely	affect	the	cost	and	availability	of	funding,	
including	placing	us	on	negative	outlook	or	on	watchlist.	
Please	note	that	a	credit	rating	is	not	a	recommendation	
to	buy,	sell,	or	hold	securities,	is	subject	to	revision	or	
withdrawal	at	any	time,	and	should	be	evaluated	
independently	of	any	other	rating.

Interest Rate & Yield Curve Risks

We	are	subject	to	interest	rate	risk	because	a	significant	
portion	of	our	business	involves	borrowing	and	lending	
money,	and	investing	in	financial	instruments.	A	
considerable	portion	of	our	funding	comes	from	short-
term	and	demand	deposits,	while	a	sizeable	portion	of	our	
lending	and	investing	is	in	medium-term	and	long-term	
instruments.	Changes	in	interest	rates	directly	impact	our	
revenues	and	expenses,	and	could	expand	or	compress	
our	net	interest	margin.	We	actively	manage	our	balance	
sheet	to	control	the	risks	of	a	reduction	in	net	interest	
margin	brought	about	by	ordinary	fluctuations	in	rates.	In	
addition,	our	fixed	income	business	tends	to	perform	
better	when	rates	decline	or	markets	are	volatile,	which	
tends	to	partially	offset	net	interest	margin	compression.

A	flat	or	inverted	yield	curve	may	reduce	our	net	interest	
margin	and	adversely	affect	our	lending	and	fixed	income	
businesses.	The	yield	curve	is	a	reflection	of	interest	rates,	
at	various	maturities,	applicable	to	assets	and	liabilities.	
The	yield	curve	is	steep	when	short-term	rates	are	much	
lower	than	long-term	rates;	it	is	flat	when	short-term	rates	
and	long-term	rates	are	nearly	the	same;	and	it	is	inverted	
when	short-term	rates	exceed	long-term	rates.	
Historically,	the	yield	curve	is	usually	upward	sloping	
(higher	rates	for	longer	terms).	However,	the	yield	curve	
can	be	relatively	flat	or	inverted	(downward	sloping),	
which	has	happened	several	times	in	the	past	few	years.	A	
flat	or	inverted	yield	curve	tends	to	decrease	net	interest	
margin,	which	would	adversely	impact	our	lending	
businesses,	and	it	tends	to	reduce	demand	for	long-term	
debt	securities,	which	would	adversely	impact	the	
revenues	of	our	fixed	income	business.	

The	U.S.	is	transitioning	away	from		“easing,”	with	the	
Federal	Reserve	indicating	its	expectations	that	bond	
purchases	will	end.	In	addition,	short-term	interest	rates	
could	be	raised,	starting	in	2022.	This	significant	change	

Reductions	in	our	credit	ratings	could	result	in	
counterparties	reducing	or	terminating	their	
relationships	with	us.	Some	parties	with	whom	we	do	
business	may	have	internal	policies	restricting	the	
business	that	can	be	done	with	financial	institutions,	such	
as	the	Bank,	that	have	credit	ratings	lower	than	a	certain	
threshold.

Reductions	in	our	credit	ratings	could	allow	some	
counterparties	to	terminate	and	immediately	force	us	to	
settle	certain	derivatives	agreements,	and	could	force	us	
to	provide	additional	collateral	with	respect	to	certain	
derivatives	agreements.	Under	our	margin	agreements,	
we	are	required	to	post	collateral	in	the	amount	of	our	
derivative	liability	positions	with	derivative	
counterparties.	FHN	could	be	asked	to	post	collateral	of	an	
undetermined	amount	based	on	changes	in	credit	ratings	
and	derivative	value.

in	direction,	and	in	the	underlying	economics	that	are	
prompting	the	change,	create	opportunities	and	risks	for	
us.		The	cessation	of	easing	should	result	in	upward	
pressure	on	long-term	interest	rates,	steepening	the	yield	
curve	and	potentially	providing	a	significant	financial	
benefit	to	us.	Raising	short-term	rates	may	re-flatten	the	
yield	curve	and	moderate	or	even	end	that	benefit,	unless	
long-term	rates	continue	to	rise	in	tandem	with	short	
rates.	See	Risks	Associated	with	Monetary	Events	
beginning	on	page	38	of	this	report	for	additional	
information.	Moreover,	the	Federal	Reserve	appears	to	be	
taking	these	actions	over	concerns	about	monetary	
inflation	and	economic	slowdown.	An	economic	slowdown	
would	adversely	impact	us	even	if	rate	moves,	in	isolation,	
would	provide	a	benefit.	See	Risks	from	Economic	
Downturns	beginning	on	page	38	for	additional	
information.

Market-indexed	deposit	products	are	very	sensitive	to	
changes	in	short-term	rates,	and	our	use	of	them	
increases	our	exposure	to	such	changes.	If	market	rates	
rise,	an	increase	in	those	deposit	rates	may	be	necessary	
before	we	are	able	to	effect	similar	increases	in	loan	rates.

Expectations	by	the	market	regarding	the	direction	of	
future	interest	rate	movements	can	impact	the	demand	
for	and	value	of	our	fixed	income	investments,	and	can	
impact	the	revenues	of	our	fixed	income	business.	This	
risk	is	most	apparent	during	times	when	strong	
expectations	have	not	yet	been	reflected	in	market	rates,	
or	when	expectations	are	especially	weak	or	uncertain.

The	expected	discontinuance	of	LIBOR	as	a	viable	
benchmark	rate	may	adversely	affect	our	business	and	
our	operating	results.	In	2017,	the	Chief	Executive	of	the	
United	Kingdom	Financial	Conduct	Authority	("FCA"),	
which	regulates	the	London	InterBank	Offered	Rate	

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Table	of	Contents

("LIBOR"),	announced	that	it	intends	to	halt	persuading	or	
compelling	banks	to	submit	rates	for	the	calculation	of	
LIBOR.	In	2021,	the	FCA	announced	that	tenors	of	U.S.	
dollar	("USD")	LIBOR	will	no	longer	be	published	as	
follows:

• One	week	and	2-month	USD	LIBOR	will	not	be	

published	after	December	31,	2021;	and

• All	other	USD	LIBOR	tenors	(e.g.,	overnight,	1-month,	
3-month,	6-month	and	12-month	tenors)	will	not	be	
published	after	June	30,	2023.

In	the	U.S.,	multiple	alternative	reference	rates	have	
become	accepted	alternatives	to	LIBOR.	These	alternatives	
include:

SOFR	and	Term	SOFR.	The	Alternative	Reference	Rates	
Committee	(“ARRC”)	is	a	group	of	private-market	
participants	convened	by	the	Federal	Reserve	Board	and	
the	Federal	Reserve	Bank	of	New	York	("New	York	Fed")	to	
help	ensure	a	successful	transition	from	USD	LIBOR	to	a	
more	robust	reference	rate.	The	ARRC	has	recommended	
the	Secured	Overnight	Financing	Rate	(“SOFR”)	as	its	
preferred	alternative.	SOFR	is	published	by	the	New	York	
Fed	but	is	not	directly	comparable	to	LIBOR	and	cannot	
easily	or	simply	be	substituted	for	it	in	outstanding	
instruments.	Key	differences	between	the	two	are:	SOFR	is	
based	on	secured	lending,	LIBOR	is	not;	and	SOFR	
historically	has	been	published	only	as	an	overnight	rate,	
while	LIBOR	is	published	in	many	short-term	forward	
looking	maturity	tenors.

Since	SOFR	is	based	on	secured	lending,	it	is	generally	
considered	a	“risk-free	rate”	whereas	LIBOR	includes	an	
implicit	credit	spread.	Currently	there	is	market-accepted	
practice	to	fully	address	this	first	difference	of	SOFR	from	
LIBOR.	In	response	to	the	second	difference,	CME	Group	
began	to	publish	Term	SOFR,	a	forward-looking	rate	with	
1-month,	3-month	and	6-month	tenors.	Term	SOFR	is	
based	on	SOFR	futures	contracts.	The	ARRC	has	
recommended	conventions	for	Term	SOFR	rates	and	has	
recommended	CME	Group	as	the	administrator	for	Term	
SOFR.	

AMERIBOR.	Another	alternative,	the	American	Interbank	
Offered	Rate	(“AMERIBOR”)	Index,	is	produced	by	the	
American	Financial	Exchange.	AMERIBOR	is	based	on	
actual	transaction	data	involving	credit	decisions	by	many	
financial	institutions,	on	an	unsecured	basis.	

BSBY.	The	Bloomberg	short-term	bank	yield	index	("BSBY")	
is	a	proprietary	rate	index	calculated	and	published	by	
Bloomberg	Index	Services	Limited.	BSBY	is	based	on	actual	
transaction	data	involving	unsecured	credit.

FHN	ceased	originating	new	loans	using	LIBOR,	and	began	
making	all	three	of	those	alternatives	available	to	most	

commercial	clients,	in	late	2021.	For	consumer	adjustable	
rate	mortgages,	FHN	offers	only	SOFR	as	the	reference	
rate,	which	FHN	believes	has	become	the	leading	
alternative	in	the	U.S.	for	that	category	of	loans.	
Outstanding	loans	affected	by	the	2021	discontinuance	of	
LIBOR	were	transitioned	to	a	new	reference	rate.	The	one-
week	and	two-month	USD	LIBOR	tenors	were	not	
commonly	used,	however;	as	a	result,	early	in	2022,	most	
of	FHN's	outstanding	pre-2022	loans	which	use	a	
reference	rate	continue	to	use	LIBOR.

The	impacts	of	this	transition	began	late	in	2021	and	will	
continue	for	several	years.	Competitive	pressures	
continue	to	constrain	our	ability	to	set	terms	using	an	
alternative	reference	rate,	and	the	industry	has	only	
modest	experience	with	how	these	alternative	rates	
behave	in	a	variety	of	contexts	and,	therefore,	what	the	
risks	are	to	the	bank,	and	to	the	client,	if	conditions	
change	after	a	loan	is	made.	As	a	result,	it	is	unclear	how	
this	transition,	and	the	fully	post-LIBOR	environment	
starting	in	mid-2023,	will	impact	our	loan	spreads	and	net	
interest	margin	overall.

As	a	lender,	an	owner	of	securities,	or	a	contractual	
counterparty,	our	primary	exposures	to	LIBOR	are	in	
variable-rate	loans	and	in	hedging	transactions.	As	
mentioned	above,	we	are	not	able	to	determine	the	
impact	on	us	that	LIBOR	discontinuance	will	have.		

A	few	instruments	issued	by	us,	including	certain	series	
of	preferred	stock	and	certain	trust	preferred	obligations,	
have	floating	rate	terms	based	on	LIBOR,	or	have	fixed	
rates	that	later	will	convert	to	floating	rate	terms	based	
on	LIBOR.		We	have	risk	that	an	adverse	outcome	of	the	
LIBOR	transition	after	the	scheduled	discontinuation	could	
increase	our	interest,	dividend,	and	other	costs	relative	to	
those	instruments.	We	may	not	be	able	to	refinance	those	
instruments	on	terms	that	reduce	those	costs	to	the	level	
we	would	have	expected	if	LIBOR	were	to	continue	
indefinitely,	unchanged.	

The	transition	from	LIBOR	may	impact	our	ability	to	use	
hedge	accounting,	which	could	impact	us	as	a	lender,	a	
securities	owner,	a	counterparty,	or	an	issuer.	Accounting	
and	tax	agencies	have	issued	guidance	that	may	ease	the	
transition,	or	at	least	clarify	the	outcomes	in	various	
situations.

Additional	information	concerning	the	risks	associated	
with	LIBOR	discontinuance	and	our	management	of	them,	
all	of	which	is	incorporated	into	this	Item	1A	by	this	
reference,	appears	under	the	caption	LIBOR	and	Reference	
Rate	Reform	within	the	Market	Uncertainties	and	
Prospective	Trends	section	of	our	2021	MD&A	(Item	7),	
which	begins	on	page	99.

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Table	of	Contents

Asset Inventories & Market Risks

ITEM	1A.	RISK	FACTORS

The	trading	securities	inventories	and	loans	held	for	sale	
in	our	fixed	income	business	are	subject	to	market	and	
credit	risks.	In	the	course	of	that	business	we	hold	trading	
securities	inventory	and	loan	positions	for	purposes	of	
distribution	to	clients,	and	we	are	exposed	to	certain	
market	risks	attributable	principally	to	interest	rate	risk	
and	credit	risk	associated	with	those	assets.	We	manage	
the	risks	of	holding	inventories	of	securities	and	loans	
through	certain	market	risk	management	policies	and	
procedures,	including,	for	example,	hedging	activities	and	
Value-at-Risk	(“VaR”)	limits,	trading	policies,	modeling,	
and	stress	analyses.	Average	fixed	income	trading	
securities	(long	positions)	were	$1.4	billion	for	2021,	2020,	
and	2019.	Average	fixed	income	trading	liabilities	(short	
positions)	were	$540	million,	$457	million,	and	$503	
million	for	2021,	2020,	and	2019,	respectively.	Average	
loans	held	for	sale	in	our	fixed	income	business	were	$563	
million,	$554	million,	and	$485	million	for	2021,	2020,	and	
2019.	Additional	information	concerning	these	risks	and	
our	management	of	them,	all	of	which	is	incorporated	into	
this	Item	1A	by	this	reference,	appears	under	the	caption	
Market	Risk	Management	beginning	on	page	91	of	our	
2021	MD&A	(Item	7).

Declines,	disruptions,	or	precipitous	changes	in	markets	
or	market	prices	can	adversely	affect	our	fees	and	other	
income	sources.	We	earn	fees	and	other	income	related	
to	our	brokerage	business	and	our	management	of	assets	
for	clients.	Declines,	disruptions,	or	precipitous	changes	in	
markets	or	market	prices	can	adversely	affect	those	
revenue	sources.

Significant	changes	to	the	securities	market’s	
performance	can	have	a	material	impact	upon	our	assets,	
liabilities,	and	financial	results.	We	have	a	number	of	
assets	and	obligations	that	are	linked,	directly	or	
indirectly,	to	major	securities	markets.	Significant	changes	
in	market	performance	can	have	a	material	impact	upon	
our	assets,	liabilities,	and	financial	results.

An	example	of	that	linkage	is	our	obligation	to	fund	our	
pension	plan	so	that	it	may	satisfy	benefit	claims	in	the	
future.	Our	pension	funding	obligations	generally	depend	
upon	actuarial	estimates	of	benefits	claims,	the	discount	
rate	used	to	estimate	the	present	values	of	those	claims,	
and	estimates	of	plan	asset	values.	Our	obligations	to	fund	
the	plan	can	be	affected	by	changes	in	any	of	those	three	
factors.	Accordingly,	our	obligations	diminish	if	the	plan’s	
investments	perform	better	than	expectations	or	if	

Mortgage Business Risks

estimates	are	changed	anticipating	better	performance,	
and	can	grow	if	those	investments	perform	poorly	or	if	
expectations	worsen.	A	rise	in	interest	rates	is	likely	to	
negatively	impact	the	values	of	fixed	income	assets	held	in	
the	plan,	but	would	also	result	in	an	increase	in	the	
discount	rate	used	to	measure	the	present	value	of	future	
benefit	payments.	Similarly,	our	obligations	can	be	
impacted	by	changes	in	mortality	tables	or	other	actuarial	
inputs.		We	manage	the	risk	of	rate	changes	by	investing	
plan	assets	in	fixed	income	securities	having	maturities	
aligned	with	the	expected	timing	of	payouts.	Because	
there	are	no	new	participants,	the	actuarial-input	risk	
should	slowly	diminish	over	time.

Changes	in	our	funding	obligation	generally	translate	into	
positive	or	negative	changes	in	our	pension	expense	over	
time,	which	in	turn	affects	our	financial	performance.	Our	
obligations	and	expenses	relative	to	the	plan	can	be	
affected	by	many	other	things,	including	changes	in	our	
participating	associate	population	and	changes	to	the	plan	
itself.	Although	we	have	taken	actions	intended	to	
moderate	future	volatility	in	this	area,	risk	of	some	level	of	
volatility	is	unavoidable.	

Our	hedging	activities	may	be	ineffective,	may	not	
adequately	hedge	our	risks,	and	are	subject	to	credit	risk.	
In	the	normal	course	of	our	businesses	we	attempt	to	
create	partial	or	full	economic	hedges	of	various,	though	
not	all,	financial	risks.	For	example:	our	fixed	income	unit	
manages	interest	rate	risk	on	a	portion	of	its	trading	
portfolio	with	short	positions,	futures,	and	options	
contracts;	we	hedge	the	risk	of	interest	rate	movements	
related	to	the	gap	between	the	time	we	originate	
mortgage	loans	and	the	time	we	sell	them;	and	we	use	
derivatives,	including	swaps,	swaptions,	caps,	forward	
contracts,	options,	and	collars,	that	are	designed	to	
moderate	the	impact	on	earnings	as	interest	rates	change.	
Generally,	in	the	last	example	these	hedged	items	include	
certain	term	borrowings	and	certain	held-to-maturity	
loans.

Hedging	creates	certain	risks	for	us,	including	the	risk	that	
the	other	party	to	the	hedge	transaction	will	fail	to	
perform	(counterparty	risk,	which	is	a	type	of	credit	risk),	
and	the	risk	that	the	hedge	will	not	fully	protect	us	from	
loss	as	intended	(hedge	failure	risk).	Unexpected	
counterparty	failure	or	hedge	failure	could	have	a	
significant	adverse	effect	on	our	liquidity	and	earnings.

Three	of	our	mortgage-related	businesses—mortgage	
origination,	title	services,	and	lending	to	mortgage	
companies—are	highly	sensitive	to	interest	rates	and	
rate	cycles.	When	rates	are	higher,	client	activity	(and	our	

related	income)	tends	to	be	muted.	Lower	rates	tend	to	
foster	higher	activity.	The	U.S.	has	experienced	extremely	
low	interest	rates	for	several	years.	Late	in	2021,	and	
continuing	in	2022,	the	Federal	Reserve	has	indicated	its	

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intention	to	start	normalizing	(raising)	interest	rates.	
Although	the	prospect	of	rate	increases	might	result	in	
higher	client	activity	for	a	brief	time,	and	although	the	
increases	being	publicly	discussed	early	in	2022	would	
leave	rates	still	very	low	by	historical	norms,	we	expect	
that	rising	rates	in	2022	and	possibly	later	will	curtail	our	
income	from	these	businesses.	That	reduction	in	business	
could	be	significant	and	fairly	sudden.	Additional	
information	concerning	rates	and	their	impacts	upon	us	is	
presented:	under	the	caption	Cyclicality	within	the	Other	
Business	Information	section	of	Item	1,	which	starts	on	
page	18;	in	Risks	Associated	with	Monetary	Events	
beginning	on	page	38;	in	Interest	Rate	and	Yield	Curve	
Risks	beginning	on	page	48;	and	under	the	caption	Federal	
Reserve	Policy	in	Transition	within	the	Market	
Uncertainties	and	Prospective	Trends	section	of	our	2021	
MD&A	(Item	7),	beginning	on	page	99.	

We	have	contractual	risks	from	our	mortgage	business.	
Our	traditional	mortgage	business	primarily	consists	of	
helping	clients	obtain	home	mortgages	which	we	sell,	
rather	than	hold,	or	which	qualify	for	a	government-
guarantee	program.	The	mortgage	terms	conform	to	the	
requirements	of	the	mortgage	buyers	or	government	
agencies,	and	we	make	representations	to	those	buyers	or	
agencies	concerning	conformity	of	each	mortgage	at	
origination.	Although	the	buyers	and	agencies	generally	
take	the	risk	that	a	mortgage	defaults,	we	retain	the	risk	
that	our	representations	were	materially	incorrect.	In	such	
a	case,	the	buyer	or	agency	generally	has	the	power	to	
force	us	to	take	the	loan	back	for	its	face	value,	or	to	make	
the	buyer	or	agency	whole	for	loss.

Pre-2009 Mortgage Business Risks

We	have	risks	from	the	mortgage-related	businesses	
legacy	First	Horizon	exited	in	2008,	including	mortgage	
loan	repurchase	and	loss-reimbursement	risk,	claims	of	
improper	foreclosure	practices,	and	claims	of	non-
compliance	with	contractual	and	regulatory	
requirements.	In	2008	we	exited	our	national	mortgage	
and	related	lending	businesses.	We	retain	the	risk	of	
liability	to	clients	and	contractual	parties	with	whom	we	
dealt	in	the	course	of	operating	those	businesses.	

Additional	information	concerning	risks	related	to	our	
former	mortgage	businesses	and	our	management	of	

Accounting & Tax Risks

Some	government	mortgage	programs	could	impose	
penalties	on	us	for	misrepresentations	at	the	time	of	
obtaining	benefits	under	the	program.	Penalties	can	be	
severe,	up	to	three	times	the	agency’s	loss.	As	a	result,	
mortgage	origination	processes	need	to	emphasize	being	
thorough	and	correct,	in	compliance	with	all	agency	
standards.	Those	processes	tend	to	slow	the	mortgage	
lending	process	for	clients,	and	increase	the	complexity	of	
the	paperwork.

The	mortgage	servicing	business	creates	regulatory	risks.		
Servicing	requires	continual	interaction	with	consumer	
clients.	Federal,	state,	and	sometimes	local	laws	regulate	
when	and	how	we	interact	with	consumer	clients.	The	
requirements	can	be	complex	and	difficult	for	us	to	
administer,	especially	if	a	client	is	having	difficulty	with	the	
mortgage	loan.	Failure	to	follow	the	applicable	rules	can	
result	in	significant	penalties	or	other	loss	for	us.

The	mortgage	servicing	business	creates	financial	
reporting	valuation	risks.	Our	contractual	right	to	service	
a	loan	generally	is	viewed	as	an	asset	for	financial	
reporting	purposes.	Servicing	rights	are	initially	recognized	
at	fair	value,	which	affects	the	gains	recognized	upon	sale	
of	the	related	loans.	Thereafter,	servicing	rights	are	
amortized	and		reviewed	for	impairment.	The	valuations	
of	servicing	rights	are	dependent	upon	a	number	of	inputs	
and	assumptions	that	require	management	judgment.	If	
our	servicing	rights	become	large	in	relation	to	our	overall	
size,	especially	in	volatile	times,	the	impact	of	valuation	
changes	can	be	significant	and	difficult	to	predict.

them,	all	of	which	is	incorporated	into	this	Item	1A	by	this	
reference,	is	set	forth:	under	the	captions	Repurchase	
Obligations	beginning	on	page	98,	and	Contingent	
Liabilities	beginning	on	page	103,	of	our	2021	MD&A	(Item	
7);	and	under	the	captions	Exposures	from	pre-2009	
Mortgage	Business	and	Mortgage	Loan	Repurchase	and	
Foreclosure	Liability,	both	within	Note	17—Contingencies	
and	Other	Disclosures	of	our	2021	Financial	Statements	
(Item	8),	which	Note	begins	on	page	168.

The	preparation	of	our	consolidated	financial	statements	
in	conformity	with	U.S.	generally	accepted	accounting	
principles	requires	management	to	make	significant	
estimates	that	affect	the	financial	statements.		The	
estimate	that	is	consistently	one	of	our	most	critical	is	the	
level	of	the	allowance	for	credit	losses.	However,	other	
estimates	can	be	highly	significant	at	discrete	times	or	

during	periods	of	varying	length,	for	example	the	
valuation	(or	impairment)	of	our	deferred	tax	assets.	
Estimates	are	made	at	specific	points	in	time.	As	actual	
events	unfold,	estimates	are	adjusted	accordingly.	Due	to	
the	inherent	nature	of	these	estimates,	it	is	possible	that,	
at	some	time	in	the	future,	we	may	significantly	increase	
the	allowance	for	credit	losses	and/or	sustain	credit	losses	

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ITEM	1A.	RISK	FACTORS

Table	of	Contents

that	are	significantly	higher	than	the	provided	allowance,	
or	we	may	recognize	a	significant	provision	for	impairment	
of	assets,	or	we	may	make	some	other	adjustment	that	
will	differ	materially	from	the	estimates	that	we	make	
today.	Moreover,	in	some	cases,	especially	concerning	
litigation	and	other	contingency	matters	where	critical	
information	is	inadequate,	often	we	are	unable	to	make	
estimates	until	fairly	late	in	a	lengthy	process.

A	significant	merger	or	acquisition	requires	us	to	make	
many	estimates,	including	the	fair	values	of	acquired	
assets	and	liabilities.	With	larger	transactions,	fair	value	
and	other	estimations	can	take	up	to	four	quarters	to	
finalize.	These	estimates,	and	their	revisions,	can	have	a	
substantial	effect	on	the	presentation	of	our	financial	
condition	and	operating	results	after	the	transaction	
closes.	In	addition,	the	excess	of	the	value	“paid”	by	us	in	
the	merger	or	acquisition	over	the	fair	value	of	the	assets	
acquired,	net	of	liabilities	assumed,	is	recorded	as	
goodwill.	Goodwill	is	subject	to	periodic	impairment	
assessment,	a	process	that	can	result	in	impairment	
expense	which	may	be	significant	and	sudden.

Changes	in	accounting	rules	can	significantly	affect	how	
we	record	and	report	assets,	liabilities,	revenues,	
expenses,	and	earnings.	Although	such	changes	generally	
affect	all	companies	in	a	given	industry,	in	practice	
changes	sometimes	have	a	disparate	impact	due	to	
differences	in	the	circumstances	or	business	operations	of	
companies	within	the	same	industry.	

One	such	accounting	change,	ASU	2016-13,	
“Measurement	of	Credit	Losses	on	Financial	
Instruments,”	substantially	revised	the	measurement	
and	recognition	of	credit	losses	for	certain	assets,	
including	most	loans,	in	a	manner	that	substantially	
changed	when	and	how	we	recognize	loan	loss.	ASU	
2016-13	was	effective	for	us	on	January	1,	2020.	Under	
ASU	2016-13,	when	we	make	or	acquire	a	new	loan,	we	
are	required	to	recognize	immediately	the	“current	
expected	credit	loss,”	or	“CECL,”	of	that	loan.	We	will	also	
re-evaluate	CECL	each	quarter	that	the	loan	is	
outstanding.	CECL	is	the	difference	between	our	cost	and	
the	net	amount	we	expect	to	collect	over	the	life	of	the	
loan	using	certain	estimation	methods	that	incorporate	
macroeconomic	forecasts	and	our	experience	with	other,	
similar	loans.	In	contrast,	the	pre-2020	accounting	
standard	delayed	recognition	until	loss	was	
“probable”	(very	likely).	We	adopted	ASU	2016-13	and	
CECL	accounting	starting	in	2020,	with	the	impact	on	
regulatory	capital	having	a	phase-in	period.	Starting	in	

2020,	recognition	of	estimated	credit	loss	was	significantly	
accelerated	compared	to	pre-CECL	practice,	which	was	
aggravated	by	the	actual	and	projected	effects	of	the	
pandemic.	Additional	information	concerning	ASU	
2016-13	appears	in	Note	1—Significant	Accounting	
Policies	within	our	2021	Financial	Statements	(Item	8)	
beginning	on	page	122,	and	in	Item	1	under	the	caption	
CECL	Accounting	and	COVID-19	within	the	section	entitled	
Significant	Business	Developments	Over	Past	Five	Years,	
which	begins	on	page	12,	all	of	which	information	is	
incorporated	into	this	Item	1A	by	reference.

In	comparison	with	former	(pre-2020)	standards,	CECL	
accounting	likely	will	continue	to:	result	in	a	significant	
increase	in	our	provision	for	credit	losses	(expense)	and	
allowance	(reserve)	during	any	period	of	loan	growth,	
including	organic	growth	and	growth	created	by	
acquisition	or	merger;	through	the	increased	provision,	
adversely	impact	our	earnings	and,	correspondingly,	our	
regulatory	capital	levels;	and	enhance	volatility	in	loan	
loss	provision	and	allowance	levels	from	quarter	to	
quarter	and	year	to	year,	especially	during	times	when	
the	economy	is	in	transition	or	experiencing	significant	
volatility.	Moreover,	once	fully	phased	in,	CECL	creates	an	
incentive	for	banks	to	reduce	new	lending	in	the	“down”	
part	of	the	economic	cycle	in	order	to	reduce	loss	
recognition	and	conserve	regulatory	capital.	That	perverse	
incentive	could,	nationwide,	prolong	a	down	cycle	in	the	
economy	and	delay	a	recovery.	

Changes	in	regulatory	rules	can	create	significant	
accounting	impacts	for	us.	Because	we	operate	in	a	
regulated	industry,	we	prepare	regulatory	financial	
reports	based	on	regulatory	accounting	standards.	
Changes	in	those	standards	can	have	significant	impacts	
upon	us	in	terms	of	regulatory	compliance.	In	addition,	
such	changes	can	impact	our	ordinary	financial	reporting,	
and	uncertainties	related	to	regulatory	changes	can	create	
uncertainties	in	our	financial	reporting.

Our	controls	and	procedures	may	fail	or	be	
circumvented.	Internal	controls,	disclosure	controls	and	
procedures,	and	corporate	governance	policies	and	
procedures	(“controls	and	procedures”)	must	be	effective	
in	order	to	provide	assurance	that	financial	reports	are	
materially	accurate.	A	failure	or	circumvention	of	our	
controls	and	procedures	or	failure	to	comply	with	
regulations	related	to	controls	and	procedures	could	have	
a	material	adverse	effect	on	our	business,	financial	
condition	and	results	of	operations.

Share Owning & Governance Risks

The	principal	source	of	cash	flow	to	pay	dividends	on	our	
stock,	as	well	as	service	our	debt,	is	dividends	and	
distributions	from	the	Bank,	and	the	Bank	may	become	
unable	to	pay	dividends	to	us	without	regulatory	
approval.	First	Horizon	Corporation	primarily	depends	

upon	common	dividends	from	the	Bank	for	cash	to	fund	
dividends	we	pay	to	our	common	and	preferred	
shareholders,	and	to	service	our	outstanding	debt.	
Regulatory	constraints	might	constrain	or	prevent	the	
Bank	from	declaring	and	paying	dividends	to	us	in	2022	

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ITEM	1A.	RISK	FACTORS

Table	of	Contents

without	regulatory	approval.	Applying	the	dividend	
restrictions	imposed	under	applicable	federal	and	state	
rules,	the	Bank’s	total	amount	available	for	dividends,	
without	obtaining	regulatory	approval,	was	$1.1	billion	at	
January	1,	2022.	

Also,	we	are	required	to	provide	financial	support	to	the	
Bank.	Accordingly,	at	any	given	time	a	portion	of	our	funds	
may	need	to	be	used	for	that	purpose	and	therefore	
would	be	unavailable	for	dividends.

Furthermore,	the	Federal	Reserve	has	issued	policy	
statements	generally	requiring	insured	banks	and	bank	
holding	companies	only	to	pay	dividends	out	of	current	
operating	earnings.	The	Federal	Reserve	has	released	a	
supervisory	letter	advising	bank	holding	companies,	
among	other	things,	that	as	a	general	matter	a	bank	
holding	company	should	inform	the	Federal	Reserve	and	
should	eliminate,	defer	or	significantly	reduce	its	
dividends	if	(i)	the	bank	holding	company’s	net	income	
available	to	shareholders	for	the	past	four	quarters,	net	of	
dividends	previously	paid	during	that	period,	is	not	
sufficient	to	fully	fund	the	dividends;	(ii)	the	bank	holding	
company’s	prospective	rate	of	earnings	is	not	consistent	
with	the	bank	holding	company’s	capital	needs	and	overall	
current	and	prospective	financial	condition;	or	(iii)	the	
bank	holding	company	will	not	meet,	or	is	in	danger	of	not	
meeting,	its	minimum	regulatory	capital	adequacy	ratios.	

Our	shareholders	may	suffer	dilution	if	we	raise	capital	
through	public	or	private	equity	financings	to	fund	our	
operations,	to	increase	our	capital,	or	to	expand.	If	we	
raise	funds	by	issuing	equity	securities	or	instruments	that	
are	convertible	into	equity	securities,	the	percentage	
ownership	of	our	current	common	shareholders	will	be	
reduced,	the	new	equity	securities	may	have	rights	and	
preferences	superior	to	those	of	our	common	or	
outstanding	preferred	stock,	and	additional	issuances	
could	be	at	a	sales	price	which	is	dilutive	to	current	
shareholders.	We	may	also	issue	equity	securities	directly	
as	consideration	for	acquisitions	we	may	make	that	would	
be	dilutive	to	shareholders	in	terms	of	voting	power	and	
share-of-ownership,	and	could	be	dilutive	financially	or	
economically.	

The	IBKC	merger,	for	example,	resulted	in	a	significant	
increase	in	our	outstanding	shares.	In	2020,	we	issued	to	
former	IBKC	shareholders	common	shares	representing	
about	44%	of	our	post-closing	outstanding	shares.	

Our	issuance	of	preferred	stock	raises	regulatory	capital	
without	issuing	common	shares,	but	creates	or	expands	
our	general	obligation	to	pay	all	preferred	dividends	
ahead	of	any	common	dividends.	Currently	we	have	six	
series	of	preferred	stock	outstanding,	one	issued	by	the	
Bank	and	five	by	First	Horizon	Corporation.	Subject	to	
capital	needs	and	market	conditions,	additional	series	may	
be	issued	in	the	future.

Provisions	of	Tennessee	law,	and	certain	provisions	of	
our	charter	and	bylaws,	could	make	it	more	difficult	for	a	
third	party	to	acquire	control	of	us	or	could	have	the	
effect	of	discouraging	a	third	party	from	attempting	to	
acquire	control	of	us.	These	provisions	could	make	it	
more	difficult	for	a	third	party	to	acquire	us	even	if	an	
acquisition	might	be	at	a	price	attractive	to	many	of	our	
shareholders.	In	addition,	federal	banking	laws	prohibit	
non-financial-industry	companies	from	owning	a	bank,	
and	require	regulatory	approval	of	any	change	in	control	
of	a	bank.

Certain	legal	rights	of	holders	of	our	common	stock	and	
of	depositary	shares	related	to	our	preferred	stock	to	
pursue	claims	against	us	or	the	depositary,	as	applicable,	
are	limited	by	our	bylaws	and	by	the	terms	of	the	deposit	
agreements.	Our	bylaws	provide	that,	unless	we	consent	
in	writing	to	an	alternative	forum,	a	state	or	federal	court	
located	within	Shelby	County	in	the	State	of	Tennessee	
will	be	the	sole	and	exclusive	forum	for	(i)	any	derivative	
action	or	proceeding	brought	in	our	right	or	name,	(ii)	any	
action	asserting	a	claim	of	breach	of	a	fiduciary	duty	owed	
by	any	director,	officer	or	other	associate	of	ours	to	us	or	
our	shareholders,	(iii)	any	action	asserting	a	claim	against	
us	or	any	director,	officer	or	other	associate	of	ours	arising	
pursuant	to	any	provision	of	the	Tennessee	Business	
Corporation	Act,	of	our	charter	or	bylaws	or	(iv)	any	action	
asserting	a	claim	against	us	or	any	director,	officer	or	
other	associate	of	ours	that	is	governed	by	the	internal	
affairs	doctrine.	In	addition,	each	deposit	agreement	
between	us	and	the	depositary,	which	govern	the	rights	of	
the	depositary	shares	related	to	our	Series	B,	C,	and	D	
preferred	stock,	provide	that	any	action	or	proceeding	
arising	out	of	or	relating	in	any	way	to	the	deposit	
agreement	may	only	be	brought	in	a	state	court	located	in	
the	State	of	New	York	or	in	the	United	States	District	Court	
for	the	Southern	District	of	New	York.	

The	foregoing	exclusive	forum	clauses	may	have	the	effect	
of	discouraging	lawsuits	against	us	or	our	directors,	
officers	or	other	associates,	or	against	the	depositary,	as	
applicable.	Exclusive	forum	clauses	may	also	lead	to	
increased	costs	to	bring	a	claim,	or	may	limit	the	ability	of	
holders	of	our	common	stock	or	depositary	shares	to	bring	
a	claim	in	a	judicial	forum	they	find	favorable.	

In	addition,	the	exclusive	forum	clauses	in	our	bylaws	and	
deposit	agreement	could	apply	to	actions	or	proceedings	
that	may	arise	under	the	federal	securities	laws,	
depending	on	the	nature	of	the	claim	alleged.	To	the	
extent	these	exclusive	forum	clauses	restrict	the	courts	in	
which	holders	of	our	common	stock	or	depositary	shares	
may	bring	claims	arising	under	the	federal	securities	laws,	
there	is	uncertainty	as	to	whether	a	court	would	enforce	
such	provisions.	These	exclusive	forum	provisions	do	not	
mean	that	holders	of	our	common	stock	or	depositary	
shares	have	waived	our	obligations	to	comply	with	the	
federal	securities	laws	and	the	rules	and	regulations	
thereunder.

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ITEM	1B.	UNRESOLVED	STAFF	COMMENTS		AND		ITEM	2.	PROPERTIES

Table	of	Contents

Item 1B. Unresolved Staff Comments

Not	applicable.

Item 2. Properties

We	own	or	lease	no	single	physical	property	that	we	
consider	to	be	materially	important	to	our	financial	
condition	or	results	from	operations.	

Our	banking	centers,	our	fixed	income	and	capital	markets	
offices,	our	title	services	offices,	our	wealth	management	
offices,	and	our	loan	origination,	processing,	and	other	
physical	offices,	in	the	aggregate,	remain	important	to	our	
ability	to	deliver	financial	services	to	a	large	portion	of	our	
clients.	For	many	years,	banking	center	usage	by	clients	
has	slowly	declined,	and	for	many	years	we	have	
consolidated	banking	center	locations	in	response	to	
changing	utilization	patterns.	We	expect	that	long-term	
trend	to	continue.	Information	concerning	our	business	
locations,	including	banking	center	and	other	client-facing	
facilities,	at	year-end	2021	is	provided	under	the	caption	
Principal	Businesses,	Brands,	&	Locations	within	the	Our	
Businesses	section	of	Item	1	of	this	report,	which	begins	
on	page	9;	that	information	is	incorporated	into	this	Item	
2	by	this	reference.	

In	addition	to	the	banking	centers	and	other	offices	
mentioned	in	Item	1,	we	own	or	lease	other	offices	and	
office	buildings,	such	as	our	headquarters	building	at	165	
Madison	Avenue	in	downtown	Memphis,	Tennessee.	
Although	some	of	these	other	offices	contain	banking	
centers	or	other	client-facing	offices,	primarily	they	are	
used	for	operational	and	administrative	functions.	Our	
operational	and	administrative	offices	are	located	in	
several	cities	where	we	have	banking	centers.	

At	December	31,	2021,	we	believe	our	physical	properties	
are	suitable	and	adequate	for	the	businesses	we	conduct.

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Table	of	Contents

ITEM	3.	LEGAL	PROCEEDINGS		AND		ITEM	4.	MINE	SAFETY	DISCLOSURES

Item 3.  Legal Proceedings

The	Contingencies	section	from	Note	17-Contingencies	and	Other	Disclosures,	beginning	on	page	168	of	this	report	within	our	
2021	Financial	Statements	(Item	8),	is	incorporated	herein	by	reference.

Item 4.  Mine Safety Disclosures

Not	applicable.

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Table	of	Contents

Supplemental Part I Information

SUPPLEMENTAL		PART	I		INFORMATION

Executive Officers of the Registrant

The	following	is	a	list	of	our	executive	officers,	as	defined	
by	Securities	and	Exchange	Commission	rules,	along	with	
certain	supplemental	information,	all	presented	as	of	
February	20,	2022.	The	executive	officers	generally	are	
elected	at	the	April	meeting	of	our	Board	of	Directors	

(following	the	annual	meeting	of	shareholders)	for	a	term	
of	one	year	and	until	their	successors	are	elected	and	
qualified.

Name	&	Age

Terry	L.	Akins
Age:	58

Elizabeth	A.	
Ardoin
Age:	52

Daryl	G.	Byrd
Age:	67

Hope	
Dmuchowski	
Age:	43
Principal	
Financial	Officer

Jeff	L.	Fleming
Age:	60
Principal	
Accounting	
Officer

D.	Bryan	Jordan
Age:	60
Principal	
Executive	Officer

Tammy	S.	
LoCascio
Age:	53

Current	(Year	First	Elected	to	Office)	and	Recent	Offices	&	Positions	
Senior	Executive	Vice	President—Chief	Risk	Officer	of	First	Horizon	&	the	Bank	(2020)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC,	Ms.	Akins	assumed	the	
role	of	Senior	Executive	Vice	President—Chief	Risk	Officer	of	First	Horizon	and	the	Bank.	Prior	to	the	
merger,	she	had	several	roles	with	IBERIABANK	Corporation	and	IBERIABANK	starting	in	2002,	the	most	
recent	of	which	was	Senior	Executive	Vice	President	and	Chief	Risk	Officer	(2017-2020).
Senior	Executive	Vice	President—Chief	Communications	Officer	of	First	Horizon	&	the	Bank	(2020)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC,	Ms.	Ardoin	assumed	the	
role	of	Senior	Executive	Vice	President—Chief	Communications	Officer	of	First	Horizon	and	the	Bank.	
Prior	to	the	merger,	she	had	several	roles	with	IBERIABANK	Corporation	and	IBERIABANK	starting	in	
2002,	the	most	recent	of	which	was	Senior	Executive	Vice	President	and	Director	of	Communications	
(2002-2020),	which	included	marketing,	public	relations,	human	resources,	and	corporate	real	estate,	
and	she	served	as	chief	of	staff	to	the	CEO.

Executive	Chairman	of	the	Board	of	First	Horizon	&	the	Bank	(2020)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC,	Mr.	Byrd	assumed	the	role	
of	Executive	Chairman	of	the	Board	of	First	Horizon	and	the	Bank.	Prior	to	the	merger,	he	served	as	
President	(1999-2020)	and	Chief	Executive	Officer	(2000-2020)	of	IBERIABANK	Corporation	and	
IBERIABANK.	Mr.	Byrd's	term	of	office	will	end	July	1,	2022.

Senior	Executive	Vice	President—Chief	Financial	Officer	of	First	Horizon	&	the	Bank	(2021)
Ms.	Dmuchowski	was	elected	to	her	current	position	in	November	2021.	Previously,	she	was	Executive	
Vice	President,	Head	of	Financial	Planning	and	Analysis	and	Management	Reporting	for	Truist	Financial	
Corp.	(Sept.-Nov.	2021);	Executive	Vice	President,	Chief	Financial	Officer	Corporate	Banking,	Commercial	
Banking	and	Corporate	Groups	for	Truist	(2019-2021);	Executive	Vice	President,	Chief	Financial	Officer	
Group	Director	for	BB&T	Corp.	(2017-2019);	and	Sr.	Vice	President,	Chief	Financial	and	Operations	
Officer—Enterprise	Operations	Services	for	BB&T	(2013-2017).	Her	career	with	BB&T,	a	predecessor	of	
Truist,	started	in	2007.
Executive	Vice	President—Chief	Accounting	Officer	and	Corporate	Controller	of	First	Horizon	&	the	
Bank	(2012)
Mr.	Fleming	assumed	the	role	of	Executive	Vice	President—Chief	Accounting	Officer	and	Corporate	
Controller	in	2012.	Previously,	starting	in	1984,	he	held	several	positions	with	us,	most	recently	(before	
his	current	role)	Executive	Vice	President—Corporate	Controller	(2010-2011).
President	and	Chief	Executive	Officer	(2008)	of	First	Horizon	&	the	Bank
Mr.	Jordan	became	President	and	Chief	Executive	Officer	in	2008.	He		was	Chairman	of	the	Board	from	
2012	until	we	closed	the	merger	of	equals	between	First	Horizon	and	IBKC	in	2020.	From	2007	until	2008	
Mr.	Jordan	was	Executive	Vice	President	and	Chief	Financial	Officer	of	First	Horizon	and	the	Bank.	From	
2000	until	2002	Mr.	Jordan	was	Comptroller,	and	from	2002	until	2007	Mr.	Jordan	was	Chief	Financial	
Officer,	of	Regions	Financial	Corp.	During	that	time	he	was	also	an	Executive	Vice	President	and	a	Senior	
Executive	Vice	President	of	Regions.
Senior	Executive	Vice	President—Chief	Operating	Officer	of	First	Horizon	&	the	Bank	(2021)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC	in	2020,	Ms.	LoCascio	
assumed	the	role	of	Senior	Executive	Vice	President—Chief	Human	Resources	Officer	of	First	Horizon	
and	the	Bank.	Prior	to	the	merger,	starting	in	2011,	she	served	in	several	roles	with	the	Bank,	most	
recently	Executive	Vice	President—Consumer	Banking	(2017-2020).	In	that	role	she	led	the	retail,	private	
client/wealth	management,	mortgage,	and	small	business	units.

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Table	of	Contents

Name	&	Age

David	T.	
Popwell
Age:	62

Anthony	J.	
Restel
Age:	52

Susan	L.	
Springfield
Age:	57

SUPPLEMENTAL		PART	I		INFORMATION

Current	(Year	First	Elected	to	Office)	and	Recent	Offices	&	Positions	
President—Specialty	Banking	of	First	Horizon	&	the	Bank	(2020)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC,	Mr.	Popwell	assumed	the	
role	of	President—Specialty	Banking	of	First	Horizon	and	the	Bank.	Prior	to	the	merger,	starting	in	2007,	
he	served	in	several	roles,	the	most	recent	of	which	(before	his	current	role)	was	President—Regional	
Banking	(2013-2020).	From	2004	to	2007	Mr.	Popwell	was	President	of	SunTrust	Bank—Memphis,	and	
prior	to	that	was	an	Executive	Vice	President	of	National	Commerce	Financial	Corp.
President—Regional	Banking	of	First	Horizon	&	the	Bank	(2021)
Following	the	closing	of	the	merger	of	equals	between	First	Horizon	and	IBKC,	Mr.	Restel	assumed	the	
role	of	Senior	Executive	Vice	President—Chief	Operating	Officer	of	First	Horizon	and	the	Bank.	From	July	
to	November	2021,	Mr.	Restel	also	acted	as	interim	Chief	Financial	Officer.	Prior	to	the	merger,	he	had	
several	roles	with	IBERIABANK	Corporation	and	IBERIABANK	starting	in	2001,	the	most	recent	of	which	
was	Vice	Chairman	and	Chief	Financial	Officer	(2005-2020).	During	his	tenure	as	Chief	Financial	Officer,	
Mr.	Restel	also	served	as	Chief	Credit	Officer	of	IBERIABANK	(2007-2009).	
Senior	Executive	Vice	President—Chief	Credit	Officer	of	First	Horizon	&	the	Bank	(2013)
Ms.	Springfield	assumed	the	role	of	Executive	Vice	President—Chief	Credit	Officer	of	First	Horizon	&	the	
Bank	in	2013,	with	“Senior”	added	to	her	title	in	2020.	Previously,	starting	in	1998,	she	served	the	Bank	
in	several	roles,	the	most	recent	of	which	(before	her	current	role)	was	Executive	Vice	President—
Commercial	Banking	(2011-2013).	

Selected Other Corporate Officers

Clyde	A.	Billings,	Jr.
Senior	Vice	President,	Assistant	
General	Counsel,	and	Corporate	
Secretary

Dane	P.	Smith
Senior	Vice	President
Corporate	Treasurer

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ITEM	5.	MARKET	FOR	COMMON	EQUITY,	STOCKHOLDER	MATTERS,	&	EQUITY	PURCHASES		AND		ITEM	6.

Table	of	Contents

PART  II

Item 5.  Market for the Registrant's Common 
Equity, Related Stockholder Matters, 
and Issuer Purchases of Equity 
Securities 

Market for Our Common Stock; Common Shareholders

Our	sole	class	of	common	stock,	$0.625	par	value,	is	listed	
and	trades	on	the	New	York	Stock	Exchange	LLC	under	the	
symbol	FHN.	At	December	31,	2021,	there	were	

approximately	9,426	shareholders	of	record	of	our	
common	stock.		

Sales of Unregistered Common and Preferred Stock

Common	Stock.	Not	applicable.
Preferred	Stock.	Not	applicable.

Repurchases by Us of Our Common Stock

Under	authorizations	from	our	Board	of	Directors,	we	may	
repurchase	shares	from	time	to	time	for	general	purposes	
and	for	our	stock	option	and	other	compensation	plans,	
subject	to	market	conditions,	accumulation	of	excess	
equity,	prudent	capital	management,	and	legal	and	
regulatory	restrictions.	We	evaluate	the	level	of	capital	
and	take	action	designed	to	generate	or	use	capital	as	
appropriate	for	the	interests	of	the	shareholders.	

Additional	information	concerning	repurchase	activity	
during	the	final	three	months	of	2021	is	presented	in	
Tables	7.22a	and	7.22b,	and	the	surrounding	notes	and	
other	text	under	the	caption	Common	Stock	Purchase	
Programs	beginning	on	page	89	of	our	2021	MD&A	(Item	
7),	which	information	is	incorporated	herein	by	this	
reference.

Total Shareholder Return Performance Graph

The	“Total	Shareholder	Return	2016-2021”	performance	
graph	appearing	on	the	next	page,	along	with	Table	5.1,	is	
“furnished”	and	not	“filed”	as	part	of	this	report,	and	is	not	
deemed	to	be	soliciting	material.	Notwithstanding	
anything	to	the	contrary	set	forth	in	this	report	or	in	any	of	
our	previous	filings	under	the	Securities	Act	of	1933,	as	
amended,	or	the	Securities	Exchange	Act	of	1934,	as	
amended,	that	might	incorporate	future	filings	by	
reference,	including	this	report	in	whole	or	in	part,	neither	
the	“Total	Shareholder	Return	2016-2021”	performance	
graph	nor	Table	5.1	shall	be	incorporated	by	reference	into	
any	such	filings.

The	“Total	Shareholder	Return	2016-2021”	performance	
graph	compares	the	yearly	percentage	change	in	our	
cumulative	total	shareholder	return	with	returns	based	on	
the	Standards	and	Poor’s	500	and	Keefe,	Bruyette	&	
Woods	(KBW)	Nasdaq	and	Regional	Bank	Indices.	The	
graph	assumes	$100	is	invested	on	December	31,	2016	
and	dividends	are	reinvested.	Returns	are	market-
capitalization	weighted.

At	year-end	2019	and	earlier,	First	Horizon	was	included	in	
the	KBW	Regional	Bank	Index.	At	year-end	2021	and	2020,	
First	Horizon	is	included	in	the	KBW	Nasdaq	Bank	Index.	
The	change	in	index	resulted	from	the	merger	of	equals	in	
2020	between	First	Horizon	and	IBERIABANK	Corporation.

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ITEM	5.	MARKET	FOR	COMMON	EQUITY,	STOCKHOLDER	MATTERS,	&	EQUITY	PURCHASES		AND		ITEM	6.

Table	of	Contents

Table	5.1		

TOTAL	SHAREHOLDER	RETURN	DATA
2017

2018

2016

2019

2020

2021

First	Horizon	Corporation

$	 100.00	 $	 101.94	 $	

68.98	 $	

89.97	 $	

73.62	 $	

97.64	

S&P	500	Index

100.00	 	

121.82	 	

116.47	 	

153.13	 	

181.29	 	

233.28	

KBW	Nasdaq	Bank	Index	(BKX)

100.00	 	

118.59	 	

97.59	 	

132.84	 	

119.15	 	

164.83	

KBW	Regional	Bank	Index	(KRX)

100.00	 	

101.81	 	

84.00	 	

104.05	 	

95.02	 	

129.84	

Source:	Bloomberg

Item 6.  [reserved]

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2021 FORM 10-K ANNUAL REPORT

		
	
	
	
    
Table	of	Contents

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Item 7.  Management's Discussion and Analysis 

of Financial Condition and Results of 
Operations

TABLE	OF	ITEM	7	TOPICS

Introduction

Executive	Overview

Results	of	Operations

Analysis	of	Financial	Condition

Capital

Risk	Management	

Repurchase	Obligations

Market	Uncertainties	and	Prospective	Trends

Critical	Accounting	Policies	and	Estimates

Non-GAAP	Information

61

61

63

70

87

90

98

99

102

104

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

Introduction

First	Horizon	Corporation	(NYSE	common	stock	trading	
symbol	“FHN”)	is	a	financial	holding	company	
headquartered	in	Memphis,	Tennessee.	FHN’s	principal	
subsidiary,	and	only	banking	subsidiary,	is	First	Horizon	
Bank.	Through	the	Bank	and	other	subsidiaries,	FHN	offers	
regional	banking,	mortgage	lending,	title	insurance,	
specialized	commercial	lending,	commercial	leasing	and	
equipment	financing,	brokerage,	wealth	management,	
capital	markets,	and	other	financial	services	to	
commercial,	consumer,	and	governmental	clients	
throughout	the	U.S.	At	December	31,	2021,	FHN	had	over	
500	business	locations	in	22	states,	including	over	400	

Executive Overview

banking	centers	in	12	states,	and	employed	more	than	
7,500	associates.	

The	following	discussion	and	analysis	is	intended	to	assist	
readers	in	understanding	the	consolidated	financial	
condition	and	results	of	operations	of	FHN.	It	should	be	
read	in	conjunction	with	the	Consolidated	Financial	
Statements	and	accompanying	Notes	to	the	Consolidated	
Financial	Statements	in	Part	II,	Item	8	of	this	Form	10-K,	as	
well	as	with	the	other	information	contained	in	this	
report.

Merger Agreement with Toronto-Dominion Bank

On	February	27,	2022,	FHN	entered	into	an	Agreement	
and	Plan	of	Merger	(the	“TD	Merger	Agreement”)	with	
The	Toronto-Dominion	Bank,	a	Canadian	chartered	bank	
(“TD”),	TD	Bank	US	Holding	Company,	a	Delaware	
corporation	and	indirect,	wholly	owned	subsidiary	of	TD	
(“TD-US”),	and	Falcon	Holdings	Acquisition	Co.,	a	
Delaware	corporation	and	wholly	owned	subsidiary	of	TD-
US	(“Merger	Sub”).

Pursuant	to	the	TD	Merger	Agreement,	FHN	and	Merger	
Sub	will	merge	(the	“First	Holding	Company	Merger”),	
with	FHN	continuing	as	the	surviving	entity	in	the	merger.		
Following	the	First	Holding	Company	Merger,	at	the	
election	of	TD,	FHN	and	TD-US	will	merge	(the	“Second	
Holding	Company	Merger”	and,	together	with	the	First	
Holding	Company	Merger,	the	“Holding	Company	
Mergers”),	with	TD-US	continuing	as	the	surviving	entity	in	
the	merger.	

Upon	the	terms	and	subject	to	the	conditions	set	forth	in	
the	TD	Merger	Agreement,	each	share	of	FHN	common	
stock,	par	value	$0.625	per	share,	(“Company	Common	
Stock”),	issued	and	outstanding	immediately	prior	to	the	
effective	time	of	the	First	Holding	Company	Merger	(the	
“First	Effective	Time”)	will	be	converted	into	the	right	to	
receive	$25.00	(USD)	per	share	in	cash,	without	interest.	If	
the	transaction	does	not	close	on	or	before	November	27,	
2022,	shareholders	will	receive	an	additional	$0.65	per	
share	of	Company	Common	Stock	on	an	annualized	basis	
(or	approximately	5.4	cents	per	month)	for	the	period	
from	November	27,	2022	through	the	day	immediately	
prior	to	the	closing.	Each	outstanding	share	of	FHN’s	
preferred	stock,	series	B,	C,	D,	E	and	F,	will	remain	issued	
outstanding	in	connection	with	the	First	Holding	Company	

IBKC Merger of Equals

Merger.	If	TD	elects	to	effect	the	Second	Holding	Company	
Merger,	at	the	effective	time	of	the	Second	Holding	
Company	Merger,	each	outstanding	share	of	FHN’s	
preferred	stock	will	be	converted	into	a	share	of	a	newly	
created,	corresponding	series	of	TD-US	having	terms	as	
described	in	the	Merger	Agreement.

Following	the	completion	of	the	First	Holding	Company	
Merger,	at	such	time	as	determined	by	TD,	First	Horizon	
Bank	and	TD	Bank,	N.A.,	a	national	banking	association	
(“TDBNA”)	will	merge,	with	TDBNA	surviving	as	a	
subsidiary	of	TD-US	(the	“Bank	Merger”	and	together	with	
the	Holding	Company	Mergers,	the	“Proposed	TD	
Merger”).

In	connection	with	the	execution	of	the	TD	Merger	
Agreement,	TD	has	agreed	to	purchase	from	FHN	shares	
of	non-voting	Perpetual	Convertible	Preferred	Stock,	
Series	G,	a	new	series	of	preferred	stock	of	FHN	(the	
“Series	G	Convertible	Preferred	Stock”)	in	a	private	
placement	transaction	having	an	aggregate	liquidation	
preference	and	purchase	price	of	approximately	$493.5	
million,	pursuant	to	a	securities	purchase	agreement	
between	FHN	and	TD	entered	into	concurrently	with	the	
execution	and	delivery	of	the	TD	Merger	Agreement.	The	
Series	G	Convertible	Preferred	Stock	is	convertible	into	up	
to	4.9%	of	the	outstanding	shares	of	Company	Common	
Stock	in	certain	circumstances,	including	the	closing	of	the	
Proposed	TD	Merger.	

Refer	to	2022	Merger	Agreement	with	Toronto-Dominion	
Bank	in	Item	1,	beginning	on	page	15,	for	additional	
information.

On	July	1,	2020,	FHN	completed	its	merger	of	equals	with	
IBERIABANK	Corporation.	FHN's	financial	results	for	2021	
reflect	the	first	full	calendar	year	of	operations	for	the	

combined	Company.	Results	for	2020	reflect	legacy	FHN	
results	prior	to	the	completion	of	the	merger	and	results	
from	both	FHN	and	IBKC	from	the	merger	closing	date	

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

forward.	FHN	expects	to	achieve	its	targeted	$200	million	
of	pre-tax	annualized	merger	cost	saves	by	the	fourth	
quarter	of	2022.

Banking Center Optimization

Banking	clients’	utilization	of	digital	capabilities	to	transact	
and	purchase	products	and	services	has	been	on	the	rise,	
and	the	impact	of	the	COVID-19	pandemic	has	accelerated	
this	trend.	In	connection	with	the	IBKC	merger	and	the	
related	impact	of	the	pandemic,	FHN	conducted	a	
comprehensive	analysis	of	its	enterprise-wide	digital	

2021 Financial Performance Summary

FHN	reported	net	income	available	to	common	
shareholders	of	$962	million,	or	$1.74	per	diluted	share,	
compared	to	net	income	of	$822	million,	or	$1.89	per	
diluted	share	in	2020	which	included	a	$533	million	
benefit,	or	$1.23	per	diluted	share,	tied	to	an	IBKC	merger	
net	purchase	accounting	gain.	

Net	interest	income	of	$2.0	billion	increased	$332	million	
from	2020	driven	by	an	increase	in	average	interest-
earning	assets	as	a	result	of	the	IBKC	merger.	Results	also	
reflect	the	benefit	of	lower	deposit	costs,	which	helped	to	
partially	offset	the	impact	of	lower	interest	rates	on	
earning	assets.		

The	provision	for	credit	losses	was	a	benefit	of	$310	
million	compared	to	an	expense	of	$503	million	in	2020,	
largely	reflecting	continued	improvement	in	the	overall	
macroeconomic	outlook,	positive	credit	grade	migration,	
and	lower	loan	balances.	The	provision	expense	for	2020	
was	impacted	by	the	adoption	of	CECL,	deterioration	in	
the	overall	macroeconomic	outlook	attributable	to	the	
COVID-19	pandemic	and	additional	provision	related	to	
acquired	non-PCD	loans.

platforms	and	its	banking	center	network.	As	a	result,	FHN	
determined	that	it	was	prudent	to	accelerate	banking	
center	closures	in	certain	markets,	resulting	in	the	closure	
of	65	banking	centers	in	2021	and	10	banking	centers	in	
first	quarter	2022.

Noninterest	income	of	$1.1	billion	decreased	$416	million	
from	2020,	largely	driven	by	the	$533	million	purchase	
accounting	gain	from	the	IBKC	merger	in	2020.	Results	
also	reflect	higher	fee	income	from	the	full-year	impact	of	
the	IBKC	merger.

Noninterest	expense	of	$2.1	billion	increased	$378	million	
from	2020	driven	by	the	impact	of	the	IBKC	merger.		

FHN	continued	to	maintain	strong	capital	measures	in	
2021.	The	Tier	1	risk-based	capital	and	total	risk-based	
capital	ratios	at	December	31,	2021	were	11.04%	and	
12.34%,	respectively,	compared	to	10.74%	and	12.57%	at	
December	31,	2020.	The	CET1	ratio	was	9.92%	at	
December	31,	2021	compared	to	9.68%	at	December	31,	
2020.

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Table	of	Contents

Table	7.1	

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

KEY	PERFORMANCE	INDICATORS

(Dollars	in	millions,	except	per	share	data)

Pre-provision	net	revenue	(a)

Diluted	earnings	per	common	share

Return	on	average	assets		(b)

Return	on	average	common	equity	(c)

Return	on	average	tangible	common	equity	(a)	(d)

Net	interest	margin	(e)

Noninterest	income	to	total	revenue	(f)

Efficiency	ratio	(g)

Allowance	for	loan	and	lease	losses	to	total	loans	and	leases
Net	charge-offs	(recoveries)	to	average	loans	and	leases

Total	period-end	equity	to	period-end	assets

Tangible	common	equity	to	tangible	assets	(a)

Cash	dividends	declared	per	common	share

Book	value	per	common	share

Tangible	book	value	per	common	share	(a)

Common	equity	Tier	1

Market	capitalization

For	the	years	ended	December	31,
2019
2020
2021

974	

$	

1,436	

$	

1.89	

$	

$	

$	

$	

$	

$	

$	

1.74	
1.15	% 	
12.53	% 	
16.46	% 	
2.48	% 	
34.77	% 	
68.56	% 	
1.22	% 	
—	% 	
9.53	% 	
6.73	% 	
0.60	

$	

14.39	

11.00	

$	

$	

631	

1.38	

1.08	%

9.60	%

1.33	% 	

13.66	% 	

19.03	% 	

14.71	%

2.86	% 	

47.41	% 	

54.37	% 	

1.65	% 	
0.26	% 	

3.28	%

35.08	%

66.15	%

0.64	%
0.09	%

9.86	% 	

11.72	%

6.89	% 	

7.48	%

0.60	

13.59	

10.23	

$	

$	

$	

0.56	

15.04	

10.02	

	9.92	%

	9.68	% 	

9.20	%

$	

8,713	

$	

7,082	

$	

5,158	

(a) Represents	a	non-GAAP	measure	which	is	reconciled	in	the	non-GAAP	to	GAAP	reconciliation	in	Table	7.30.
(b) Calculated	using	net	income	divided	by	average	assets.
(c) Calculated	using	net	income	available	to	common	shareholders	divided	by	average	common	equity.
(d) Calculated	using	net	income	available	to	common	shareholders	divided	by	average	tangible	common	equity.
(e) Net	interest	margin	is	computed	using	total	net	interest	income	adjusted	to	an	FTE	basis	assuming	a	statutory	federal	income	tax	rate	

of	21%	and,	where	applicable,	state	income	taxes.

(f) Ratio	is	noninterest	income	excluding	securities	gains	(losses)	to	total	revenue	excluding	securities	gains	(losses).
(g) Ratio	is	noninterest	expense	to	total	revenue	excluding	securities	gains	(losses).

Results of Operations—2021 compared to 2020

Net Interest Income

Net	interest	income	is	FHN's	largest	source	of	revenue	and	
is	the	difference	between	the	interest	earned	on	interest-
earning	assets	(generally	loans,	leases	and	investment	
securities)	and	the	interest	expense	incurred	in	
connection	with	interest-bearing	liabilities	(generally	
deposits	and	borrowed	funds).	The	level	of	net	interest	
income	is	primarily	a	function	of	the	difference	between	
the	effective	yield	on	average	interest-earning	assets	and	
the	effective	cost	of	interest-bearing	liabilities.	These	
factors	are	influenced	by	the	pricing	and	mix	of	interest-
earning	assets	and	interest-bearing	liabilities	which,	in	
turn,	are	impacted	by	external	factors	such	as	local	
economic	conditions,	competition	for	loans	and	deposits,	
the	monetary	policy	of	the	FRB	and	market	interest	rates.

Net	interest	income	of	$2.0	billion	in	2021	increased	20%	
from	2020	driven	by	the	impact	of	the	IBKC	merger.	
Results	also	reflect	the	benefit	of	lower	deposit	costs	

which	helped	to	partially	offset	the	impact	of	lower	
interest-earning	asset	yields	and	spreads.

FHN's	net	interest	margin	decreased	38	basis	points	from	
2020	to	2.48%	in	2021	and	the	net	interest	spread	
decreased	32	basis	points	to	2.36%	over	the	same	period.	
Net	interest	margin	and	net	interest	spread	were	
unfavorably	impacted	by	a	58	basis	point	decrease	in	
earning	asset	yields,	largely	reflecting	the	impact	of	lower	
interest	rates	and	higher	levels	of	excess	cash.	The	lower	
yield	on	earning	assets	was	partially	offset	by	a	26	basis	
point	decrease	in	the	cost	of	interest-bearing	liabilities	
driven	by	lower	deposit	costs.		

The	following	table	presents	the	major	components	of	net	
interest	income	and	net	interest	margin:

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Table	of	Contents

Table	7.2		

(Dollars	in	millions)

Assets:
Loans	and	leases:

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

AVERAGE	BALANCES,	NET	INTEREST	INCOME	AND	YIELDS/RATES

2021

Interest	
Income/
Expense

Average	
Balance

Yield/
Rate	

Average	
Balance

2020

Interest	
Income/
Expense

Yield/
Rate	

Average	
Balance

2019

Interest	
Income/
Expense

Yield/
Rate	

		Commercial	loans	and	leases

$	 44,325	 $	 1,498	

		Consumer	loans

Total	loans	and	leases

Loans	held	for	sale

Investment	securities

Trading	securities

Federal	funds	sold

Securities	purchased	under	agreements	to	

resell	(a)

Interest-bearing	deposits	with	banks

	 11,973	

	 56,298	

956	

8,623	

1,366	

37	

584	
	 13,123	

33	

	 3.44	

123	

	 1.43	

	 2.17	

	 0.15	

30	

—	

—	
17	

	 3.38	% $	 36,146	 $	 1,324	
407	
	 10,037	
	 3.92	

	 3.66	% $	 22,385	 $	 1,091	

	 4.87	%

	 4.05	

6,804	

311	

	 4.57	

469	

1,967	

	 3.49	

	 46,183	

1,731	

	 3.75	

	 29,189	

1,402	

	 4.80	

835	

6,464	

1,433	

42	

30	

	 3.60	

106	

	 1.64	

35	

—	

	 2.44	

	 0.21	

2	
	(0.09)	
5	
	 0.13	
	 2.68	% $	 58,468	 $	 1,909	

505	
3,006	

	 0.45	
	 0.14	

578	

4,510	

1,415	

48	

555	
871	

31	

	 5.39	

121	

	 2.69	

47	

	 3.33	

1	

	 2.63	

11	
20	

	 1.96	
	 2.18	

Total	earning	assets	/	Total	interest	income	

$	 80,987	 $	 2,170	

	 3.26	% $	 37,166	 $	 1,633	

	 4.39	%

Cash	and	due	from	banks
Goodwill	and	other	intangible	assets,	net	

Premises	and	equipment,	net	

Allowance	for	loan	and	lease	losses	

Other	assets	

Total	assets	

Liabilities	and	Shareholders'	Equity:
Interest-bearing	deposits:

		Savings

		Other	interest-bearing	deposits

		Time	deposits

Total	interest-bearing	deposits

Federal	funds	purchased

Securities	sold	under	agreements	to	

repurchase

Trading	liabilities

Other	short-term	borrowings

Term	borrowings

Total	interest-bearing	liabilities	/	Total	

interest	expense

Noninterest-bearing	deposits

Other	liabilities

Total	liabilities	

Shareholders'	equity

Noncontrolling	interest

Total	shareholders'	equity

1,261	
1,836	

712	

(834)	

3,647	

852	
1,696	

604	

(700)	

3,426	

602	
1,575	

467	

(191)	

2,125	

$	 87,609	

$	 64,346	

$	 41,744	

$	 27,283	 $	

	 15,688	

4,281	

	 47,252	

36	

20	

25	

81	

	 0.13	% $	 19,780	 $	
	 0.13	

	 11,973	

	 0.57	

	 0.17	

4,347	

82	

31	

39	

	 0.41	% $	 11,663	 $	

144	

	 1.24	%

	 0.26	

	 0.90	

8,345	

4,262	

79	

84	

	 0.94	

	 1.97	

	 36,100	

152	

	 0.42	

	 24,270	

307	

	 1.27	

949	

1	

	 0.12	

862	

3	

	 0.34	

1,235	

540	

124	

1,645	

4	

6	

—	

72	

	 0.30	

	 1.11	

	 0.09	

	 4.37	

1,109	

457	

626	

1,578	

6	

6	

5	

	 0.50	

	 1.24	

	 0.84	

64	

	 4.02	

1,117	

738	

701	

503	

538	

15	

	 2.08	

15	

13	

11	

53	

	 2.07	

	 2.48	

	 2.10	

	 4.77	

$	 51,745	 $	

164	

	 0.32	% $	 40,732	 $	

236	

	 0.58	% $	 27,867	 $	

414	

	 1.49	%

	 25,879	

1,506	

	 79,130	

8,184	

295	

8,479	

	 15,779	

1,226	

	 57,737	

6,314	

295	

6,609	

$	 64,346	

8,133	

824	

	 36,824	

4,625	

295	

4,920	

$	 41,744	

Total	liabilities	and	shareholders'	equity

$	 87,609	

Net	earnings	assets	/	Net	interest	income	

(TE)		/	Net	interest	spread

Taxable	equivalent	adjustment

$	 29,242	 $	 2,006	

(12)	

	 2.36	% $	 17,736	 $	 1,673	
(11)	
	 0.12	

	 2.68	% $	 9,299	 $	 1,219	

	 2.90	%

	 0.18	

(9)	

	 0.38	

Net	interest	income	/	Net	interest	margin	(b)

$	 1,994	

	 2.48	%

$	 1,662	

	 2.86	%

$	 1,210	

	 3.28	%

(a)	Negative	yield	is	driven	by	negative	market	rates	on	reverse	repurchase	agreements.	
(b)	Calculated	using	total	net	interest	income	adjusted	for	FTE	assuming	a	statutory	federal	income	tax	rate	of	21%,	and	where	applicable,	state	income	taxes.	

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

The	following	table	presents	the	change	in	interest	income	and	interest	expense	due	to	changes	in	both	average	volume	and	
average	rate.	

Table	7.3		

ANALYSIS	OF	CHANGES	IN	NET	INTEREST	INCOME

(Dollars	in	millions)

Interest	income:

Loans	and	leases

Loans	held	for	sale

Investment	securities

Trading	securities

Other	earning	assets:

Federal	funds	sold

Securities	purchased	under	agreements	to	resell

Interest-bearing	deposits	with	banks	

Total	other	earning	assets

2021	Compared	to	2020

2020	Compared	to	2019

Increase	(Decrease)	Due	to	(a)

Increase	(Decrease)	Due	to	(a)

Rate	(b)

Volume	(b)

	Total

Rate	(b)

Volume	(b)

	Total

$	

(119)	 $	

354	 $	

235	

$	

(361)	 $	

689	 $	

328	

(1)	

(15)	

(4)	

—	

(3)	

—	

(3)	

4	

31	

(1)	

—	

1	

13	

14	

3	

16	

(5)	

—	

(2)	

13	

11	

(12)	

(58)	

(12)	

(1)	

(8)	

(30)	

(39)	

11	

42	

—	

—	

(1)	

15	

14	

(1)	

(16)	

(12)	

(1)	

(9)	

(15)	

(25)	

Total	change	in	interest	income	-	earning	assets	

$	

(142)	 $	

402	 $	

260	

$	

(482)	 $	

756	 $	

274	

Interest	expense:

Interest-bearing	deposits:

Savings

Time	deposits

Other	interest-bearing	deposits

Total	interest-bearing	deposits

Federal	funds	purchased

Securities	sold	under	agreements	to	repurchase

Trading	liabilities

Other	short-term	borrowings

Term	borrowings

$	

(69)	 $	

23	 $	

(46)	 $	

(129)	 $	

66	 $	

(14)	

(11)	

(71)	

(2)	

(3)	

—	

(4)	

8	

(47)	

(72)	

(248)	

(14)	

(13)	

(6)	

(9)	

(9)	

2	

25	

93	

2	

5	

(1)	

2	

20	

(63)	

(45)	

(47)	

(155)	

(12)	

(8)	

(7)	

(7)	

11	

(14)	

(19)	

(102)	

(2)	

(3)	

(1)	

1	

5	

—	

8	

31	

—	

—	

1	

(5)	

3	

30	

Total	change	in	interest	expense	-	interest-bearing	
liabilities

(102)	

(72)	

(299)	

121	

(178)	

Net	interest	income	

$	

(40)	 $	

372	 $	

332	

$	

(183)	 $	

635	 $	

452	

(a)		 The	changes	in	interest	due	to	both	rate	and	volume	have	been	allocated	to	change	due	to	rate	and	change	due	to	volume	in	proportion	to	the	absolute	

amounts	of	the	changes	in	each.

(b)	 Variances	are	computed	on	a	line-by-line	basis	and	are	non-additive.

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Provision for Credit Losses

Provision	for	credit	losses	includes	the	provision	for	loan	
and	lease	losses	and	the	provision	for	unfunded	lending	
commitments.	The	provision	for	credit	losses	is	the	
expense	necessary	to	maintain	the	ALLL	and	the	accrual	
for	unfunded	lending	commitments	at	levels	appropriate	
to	absorb	management’s	estimate	of	credit	losses	
expected	over	the	life	of	the	loan	and	lease	portfolio	and	
the	portfolio	of	unfunded	loan	commitments.	

Provision	for	credit	losses	improved	to	a	provision	benefit	
of	$310	million	in	2021,	compared	to	an	expense	of	

Noninterest Income 

$503	million	in	2020,	largely	reflecting	an	improvement	in	
the	overall	macroeconomic	outlook,	positive	credit	grade	
migration	and	lower	loan	balances.	The	provision	in	2020	
was	driven	by	the	adoption	of	CECL	and	the	impact	of	the	
COVID-19	pandemic	on	loss	expectations.	Results	in	2020	
also	reflect	the	impact	of	the	IBKC	merger	and	Truist	
branch	acquisition,	including	$147	million	related	to	non-
PCD	loans.	For	additional	information	about	general	asset	
quality	trends	refer	to	the	Asset	Quality	section	in	this	
MD&A.	

The	following	table	presents	the	significant	components	of	noninterest	income	for	each	of	the	periods	presented:

Table	7.4

(Dollars	in	millions)

Noninterest	income

Fixed	income

Deposit	transactions	and	cash	
management

Mortgage	banking	and	title	income

Brokerage,	management	fees	and	
commissions

Card	and	digital	banking	fees

Trust	services	and	investment	
management

	Other	service	charges	and	fees

Securities	gains	(losses),	net

Purchase	accounting	gain

Other	income

NONINTEREST	INCOME

2021	vs.	2020

2020	vs.	2019

2021

2020

2019

$	Change	 %	Change

$	Change

%	Change

$	

406	 $	

423	 $	

279	 $	

(17)	

	(4)	% $	

144	

175	

154	

88	

78	

51	

44	

13	

(1)	

68	

148	

129	

66	

60	

39	

26	

(6)	

533	

74	

132	

10	

55	

49	

30	

21	

—	

—	

78	

27	

25	

22	

18	

12	

18	

19	

	18	% 	

	19	% 	

	33	% 	

	30	% 	

	31	% 	

	69	% 	

NM 	

(534)	

	(100)	% 	

(6)	

	(8)	% 	

16	

119	

11	

11	

9	

5	

(6)	

533	

(4)	

	52	%

	12	%

NM

	20	%

	22	%

	30	%

	24	%

	(100)	%

	100	%

	(5)	%

	128	%

Total	noninterest	income

$	

1,076	 $	

1,492	 $	

654	 $	

(416)	

	(28)	% $	

838	

NM	–	Not	meaningful

Noninterest	income	totaled	$1.1	billion	in	2021	and	
$1.5	billion	in	2020,	or	35%	and	47%	of	total	revenue,	
respectively.	The	decrease	in	noninterest	income	in	2021	
was	driven	by	a	$534	million	reduction	tied	to	the	
purchase	accounting	gain	recorded	in	2020	related	to	the	
IBKC	merger.	Results	also	reflect	the	benefit	of	higher	fee	
income	largely	driven	by	the	full-year	impact	of	the	IBKC	
merger.	

Fixed	income	revenues	are	mainly	generated	from	the	
purchase	and	sale	of	fixed	income	securities	as	both	
principal	and	agent.	Other	noninterest	revenues	within	
this	line	item	consist	principally	of	fees	from	derivative	
sales,	portfolio	advisory	services	and	loan	sales.	Fixed	
income	fees	of	$406	million	decreased	$17	million	from	
exceptionally	strong	levels	in	2020.	Fixed	income	product	
revenue	decreased	$10	million,	reflecting	slightly	less	
favorable	market	conditions,	while	revenue	from	other	

products	decreased	$7	million,	largely	driven	by	lower	
fees	from	derivative	and	loan	sales,	somewhat	offset	by	
higher	fees	from	portfolio	advisory	services.	Fixed	income	
average	daily	revenue	of	$1.4	million	in	2021	decreased	
slightly	from	$1.5	million	in	2020.	

Deposit	transactions	and	cash	management	fees	of	
$175	million	increased	$27	million,	or	18%,	from	2020,	
primarily	driven	by	the	impact	of	the	IBKC	merger	and	
Truist	branch	acquisition.	

Mortgage	banking	and	title	income	of	$154	million	
increased	$25	million	from	$129	million	in	2020	as	the	
benefit	of	the	IBKC	merger	was	partially	offset	by	a	
strategic	shift	in	origination	mix	toward	portfolio	loans	as	
well	as	lower	spreads	on	sales	of	mortgage	loans.

Brokerage,	management	fees	and	commissions	include	
fees	for	portfolio	management,	trade	commissions,	and	

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annuity	and	mutual	funds	sales.	These	fees	and	
commissions	totaled	$88	million	in	2021,	an	increase	of	
33%	compared	to	$66	million	in	2020	driven	by	the	impact	
of	the	IBKC	merger	and	an	increase	in	annuity	income	and	
advisory	fees.	

Trust	services	and	investment	management	income	of	
$51	million	increased	$12	million	from	2020,	driven	by	the	
impact	of	the	IBKC	merger	as	well	as	new	business	and	
market	appreciation.

Noninterest Expense

The	IBKC	merger	also	drove	the	increases	in	card	and	
digital	banking	fees	and	other	service	charges	and	fees	in	
2021	compared	to	2020.

Other	income	in	2021	included	a	$26	million	loss	on	the	
redemption	of	legacy	IBKC	trust	preferred	securities.

The	following	table	presents	the	significant	components	of	noninterest	expense	for	each	of	the	periods	presented:

Table	7.5

(Dollars	in	millions)

Noninterest	expense

Personnel	expense

Net	occupancy	expense

Computer	software

Operations	services

Legal	and	professional	fees

Contract	employment	and	outsourcing

Amortization	of	intangible	assets

Equipment	expense

Communications	and	delivery

Advertising	and	public	relations

Impairment	of	long-lived	assets

Contributions

Other	expense

NONINTEREST	EXPENSE

2021	vs.	2020

2020	vs.	2019

2021

2020

2019

$	Change %	Change

$	Change %	Change

$	

1,210	 $	

1,033	 $	

695	

$	

177	

	17	% $	

338	

137	

116	

80	

68	

67	

56	

47	

37

37

34	

14	

116	

85	

56	

84	

24	

40	

42	

31

18

7	

41	

80	

61	

46	

72	

13	

25	

34	

25

34

23	

11	

193

141

114

21

31

24

(16)	

43

16

5

6

19

27

(27)	

52

378	

	18	%

	36	%

	43	%

	(19)	%

NM

	40	%

	12	%

	19	%

NM 	

NM 	

	(66)	%

	37	%

36

24

10

12

11

15

8

6

(16)	

(16)	

30

27

	22	% $	

485	

	49	%

	45	%

	39	%

	22	%

	17	%

	85	%

	60	%

	24	%

	24	%

	(47)	%

	(70)	%

NM

	24	%

	39	%

Total	noninterest	expense

$	

2,096	 $	

1,718	 $	

1,233	

$	

NM	-	Not	meaningful

Total	noninterest	expense	of	$2.1	billion	increased	$378	
million,	or	22%,	driven	by	the	impact	of	the	IBKC	merger,	
mitigated	in	part	by	a	reduction	in	noninterest	expense	as	
a	result	of	expense	discipline	and	merger	cost	saves.	Total	
merger/acquisition	integration	expense	was	$187	million	
in	2021	compared	to	$155	million	in	2020.

Personnel	expense	of	$1.2	billion	increased	$177	million	
from	2020	driven	by	the	full-year	impact	of	the	IBKC	
merger	and	Truist	branch	acquisition.	Results	also	reflect	
lower	merger/acquisition	integration	expenses	of	$10	
million,	primarily	severance	and	retention	costs,	and	the	
benefit	of	merger	cost	saves.	Deferred	compensation	
expense,	a	component	of	personnel	expense,	increased	$9	
million	in	2021,	largely	due	to	$6	million	from	litigation	
tied	to	a	company	that	was	fully	divested	over	ten	years	
ago.

The	increases	in	net	occupancy	expense	and	computer	
software	expense	in	2021	were	both	driven	by	the	impact	
of	the	IBKC	merger	and	Truist	branch	acquisition.	

Operations	services	expense	increased	$24	million,	or	
43%,	to	$80	million	in	2021,	driven	by	the	impact	of	the	
IBKC	merger	and	a	$7	million	increase	in	merger/
acquisition	integration	expense.		

Legal	and	professional	fees	decreased	$16	million,	or	19%,	
to	$68	million	in	2021,	driven	by	an	$18	million	decline	in	
merger/acquisition	integration	expense.	

Contract	employment	and	outsourcing	increased	
$43	million	driven	by	the	impact	of	the	IBKC	merger,	
higher	contractor	costs	tied	to	investments	in	new	
systems	and	an	$11	million	increase	in	merger/acquisition	
integration	expense.

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Amortization	of	intangible	assets	of	$56	million	in	2021	
increased	$16	million	compared	to	2020	primarily	due	to	
amortization	tied	to	the	intangible	assets	created	from	the	
IBKC	merger.

Advertising	and	public	relations	of	$37	million	increased	
$19	million	from	2020	largely	driven	by	a	$10	million	
increase	in	merger/acquisition	integration	expense.	

Impairment	of	long-lived	assets	of	$34	million	and	
$7	million	in	2021	and	2020,	respectively,	was	primarily	
related	to	merger	integration	efforts	associated	with	
reduction	of	leased	office	space	and	banking	center	
optimization.

Contributions	decreased	$27	million	in	2021,	primarily	due	
to	a	$20	million	contribution	to	the	Louisiana	First	Horizon	

Income Taxes

FHN	recorded	income	tax	expense	of	$274	million	in	2021	
compared	to	$76	million	in	2020,	resulting	in	an	effective	
tax	rate	of	21.4%	and	8.2%	respectively.	The	lower	
effective	tax	rate	in	2020	was	primarily	the	result	of	the	
purchase	accounting	gain	from	the	IBKC	merger,	which	
was	not	included	in	taxable	income.	

FHN’s	effective	tax	rate	is	favorably	affected	by	recurring	
items	such	as	bank-owned	life	insurance,	tax-exempt	
income,	and	tax	credits	and	other	tax	benefits	from	tax	
credit	investments.	The	effective	rate	is	unfavorably	
affected	by	the	non-deductibility	of	portions	of:	FDIC	
premium,	executive	compensation	and	merger	expenses.	
FHN's	effective	tax	rate	also	may	be	affected	by	items	that	
may	occur	in	any	given	period	but	are	not	consistent	from	
period	to	period,	such	as	changes	in	unrecognized	tax	
benefits.	The	rate	also	may	be	affected	by	items	resulting	
from	business	combinations.

A	deferred	tax	asset	or	deferred	tax	liability	is	recognized	
for	the	tax	consequences	of	temporary	differences	
between	the	financial	statement	carrying	amounts	and	
the	tax	bases	of	existing	assets	and	liabilities.	The	tax	
consequence	is	calculated	by	applying	current	enacted	
statutory	tax	rates	to	these	temporary	differences	in	
future	years.	FHN’s	net	DTA	was	$52	million	and	less	than	
$1	million	at	December	31,	2021	and	2020,	respectively.	

As	of	December	31,	2021,	FHN	had	deferred	tax	asset	
balances	related	to	federal	and	state	income	tax	
carryforwards	of	$38	million	and	$2	million,	which	will	

Business Segment Results

During	2020,	FHN	reorganized	its	internal	management	
structure	and,	accordingly,	its	segment	reporting	
structure.	Historically,	FHN's	primary	business	segments	
were	Regional	Banking,	Fixed	Income,	Corporate,	and	
Non-strategic.	The	closing	of	the	FHN	and	IBKC	merger	of	
equals	transaction	prompted	organizational	changes	to	
better	integrate	and	execute	the	combined	Company's	

Foundation	in	connection	with	the	IBKC	merger	and	a	$15	
million	donation	of	Paycheck	Protection	Plan	fees	to	the	
First	Horizon	Foundation	to	assist	low-	and	moderate-
income	communities	in	2020.	Contributions	in	2021	reflect	
an	increase	in	other	contributions	to	the	First	Horizon	
Foundation.

The	$52	million	increase	in	other	expense	in	2021	was	
largely	attributable	to	$19	million	in	derivative	valuation	
adjustments	on	prior	Visa	Class	B	share	sales	and	
increases	in	customer	relations,	loan	closing,	fraud,	and	
travel	and	entertainment	expenses.

expire	at	various	dates.	Refer	to	Note	15	-	Income	Taxes	
for	additional	information.

FHN’s	gross	DTA	after	valuation	allowance	was	$448	
million	and	$471	million	as	of	December	31,	2021	and	
2020,	respectively.	Based	on	current	analysis,	FHN	
believes	that	its	ability	to	realize	the	DTA	is	more	likely	
than	not.	FHN	monitors	its	DTA	and	the	need	for	a	
valuation	allowance	on	a	quarterly	basis.	A	significant	
adverse	change	in	FHN’s	taxable	earnings	outlook	could	
result	in	the	need	for	a	valuation	allowance.	

FHN	and	its	eligible	subsidiaries	are	included	in	a	
consolidated	federal	income	tax	return.	FHN	files	separate	
returns	for	subsidiaries	that	are	not	eligible	to	be	included	
in	a	consolidated	federal	income	tax	return.	Based	on	the	
laws	of	the	applicable	states	where	it	conducts	business	
operations,	FHN	either	files	consolidated,	combined,	or	
separate	returns.	The	statute	of	limitations	for	FHN’s	
consolidated	federal	income	tax	returns	remains	open	for	
tax	years	2018	through	2020.	Additionally,	2016	–	2017	
could	be	subject	to	limited	review	related	to	refund	claims	
filed.	IBKC's	federal	consolidated	tax	returns	for	2016,	
2017	and	2018	are	currently	under	examination	by	the	
IRS.	On	occasion,	as	federal	or	state	auditors	examine	the	
tax	returns	of	FHN	and	its	subsidiaries,	FHN	may	extend	
the	statute	of	limitations	for	a	reasonable	period.		
Otherwise,	the	statutes	of	limitations	remain	open	only	
for	tax	years	in	accordance	with	federal	and	state	statutes.			
See	Note	15	-	Income	Taxes	for	additional	information.

strategic	priorities	across	all	lines	of	businesses.	As	a	
result,	FHN	revised	its	reportable	segments	to	include	
Regional	Banking,	Specialty	Banking	and	Corporate.	
Segment	results	for	years	prior	to	2020	have	been	recast	
to	adjust	for	the	realignment	of	the	segment	reporting	
structure.	See	Note	20	-	Business	Segment	Information	for	

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

additional	disclosures	related	to	FHN's	operating	
segments.	

which	helped	to	partially	offset	the	impact	of	lower	
interest-earning	asset	yields	and	spreads.

Regional	Banking

The	Regional	Banking	segment	generated	pre-tax	income	
of	$1.3	billion	in	2021	compared	to	$273	million	in	2020,	
reflecting	the	impact	of	the	IBKC	merger	and	a	decrease	in	
the	provision	for	credit	losses	resulting	from	improvement	
in	the	macroeconomic	outlook,	positive	credit	grade	
migration	and	lower	loan	balances.

Net	interest	income	increased	$500	million,	or	40%,	in	
2021,	largely	driven	by	merger-related	earning	asset	
growth.	Results	also	reflect	the	benefit	of	lower	deposit	
costs	which	helped	to	partially	offset	the	impact	of	lower	
interest-earning	asset	yields	and	spreads.

Noninterest	income	increased	$93	million,	or	27%,	largely	
attributable	to	increases	in	fee	income	driven	by	the	
impact	of	the	IBKC	merger.

Noninterest	expense	of	$1.2	billion	in	2021,	increased	
$207	million,	or	22%,	from	2020,	primarily	as	a	result	of	
the	impact	of	the	IBKC	merger,	mitigated	in	part	by	
expense	discipline	and	the	benefit	of	merger	cost	saves.	

Specialty	Banking

Pre-tax	income	in	the	Specialty	Banking	segment	
increased	$171	million	to	$709	million	in	2021,	largely	
driven	by	a	decrease	of	$180	million	in	the	provision	for	
credit	losses.	

Net	interest	income	increased	$47	million,	or	8%,	in	2021	
largely	driven	by	merger-related	earning	asset	growth.	
Results	also	reflect	the	benefit	of	lower	deposit	costs	

Noninterest	income	increased	$21	million,	or	4%,	from	
2020.	Mortgage	banking	and	title	income	increased	$24	
million,	or	19%,	as	the	benefit	of	the	IBKC	merger	was	
offset	by	an	intentional	shift	in	origination	mix	toward	
portfolio	loans	as	well	as	lower	gain	on	sale	spreads.	Fixed	
income	was	down	$16	million,	or	4%,	from	2020,	
reflecting	slightly	less	favorable	market	conditions	and	
lower	fees	from	derivative	and	loan	sales,	somewhat	
offset	by	higher	fees	from	portfolio	advisory	services.		

Noninterest	expense	increased	$77	million,	or	16%,	to	
$571	million	in	2021,	largely	attributable	to	higher	
personnel	and	outside	services	costs	from	the	impact	of	
the	IBKC	merger.	

Corporate

Pre-tax	loss	for	the	Corporate	segment	was	$705	million	
for	2021	compared	to	pre-tax	income	of	$122	million	for	
2020.	Results	for	2021	reflect	a	decline	in	revenue	largely	
tied	to	the	IBKC	purchase	accounting	gain	in	2020,	a	$215	
million	decrease	in	net	interest	income	resulting	from	the	
impact	of	funds	transfer	pricing,	and	a	$26	million	loss	on	
the	redemption	of	legacy	IBKC	trust	preferred	securities	in	
2021.	In	addition,	noninterest	expense	increased	$94		
million,	largely	attributable	to	merger	and	integration-
related	costs	including	asset	impairments	associated	with	
the	reduction	of	leased	office	space	and	banking	center	
optimization	as	well	as	$19	million	in	derivative	valuation	
adjustments	on	prior	Visa	Class	B	share	sales.

Results of Operations—2020 compared to 2019

For	a	description	of	FHN's	results	of	operations	for	2020,	see	Results	of	Operations	-	2020	compared	to	2019	in	Item	7	in	the	
2020	Form	10-K.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

Analysis of Financial Condition

Investment Securities

The	following	table	presents	the	carrying	value	of	securities	by	category	as	of	December	31	for	the	years	indicated:

Table	7.6	

COMPOSITION	OF	SECURITIES	PORTFOLIO

(Dollars	in	millions)

Securities	available	for	sale:
U.S.	treasuries

Government	agency	issued	MBS	and	CMO

Other	U.S.	government	agencies	(a)

Corporate	and	other	debt

States	and	municipalities

SBA	interest-only	strips

Total	securities	available	for	sale

Securities	held	to	maturity:

Government	agency	issued	MBS	and	CMO

Corporate	and	other	debt

Total	securities	held	to	maturity

Total	investment	securities	

2021

2020

Balance

Mix

Balance

Mix

$	

$	

$	

$	

$	

—	

7,312	

850	

—	

545	

—	

	—	% $	
	78	

613	

6,218	

	9	

	—	

	6	

	—	

684	

40	

460	

32	

	8	%

	77	

	9	

	—	

	6	

	—	

8,707	

	93	% $	

8,047	

	100	%

712	

—	

712	

	7	% $	

—	

	7	% $	

—	

10	

10	

	—	%

	—	

	—	%

9,419	

	100	% $	

8,057	

	100	%

(a)	Includes	securities	issued	by	government	sponsored	entities	which	are	not	backed	by	the	full	faith	and	credit	of	the	U.S.	Government.

FHN’s	investment	portfolio	consists	principally	of	debt	
securities	available	for	sale.	FHN	maintains	a	highly-rated	
securities	portfolio	consisting	primarily	of	government	
agency	issued	mortgage-backed	securities	and	
collateralized	mortgage	obligations.	The	securities	
portfolio	provides	a	source	of	income	and	liquidity	and	is	
an	important	tool	used	to	balance	the	interest	rate	risk	of	
the	loan	and	deposit	portfolios.	The	securities	portfolio	is	
periodically	evaluated	in	light	of	established	ALM	
objectives,	changing	market	conditions	that	could	affect	
the	profitability	of	the	portfolio,	the	regulatory	
environment,	and	the	level	of	interest	rate	risk	to	which	
FHN	is	exposed.	These	evaluations	may	result	in	steps	
taken	to	adjust	the	overall	balance	sheet	positioning.	
During	the	third	quarter	of	2021,	in	order	to	improve	net	

interest	income	and	moderate	a	portion	of	its	overly	asset	
sensitive	interest	rate	risk	position,	FHN	began	deploying	
excess	cash	into	the	investment	portfolio	by	purchasing	
securities	classified	as	held	to	maturity.	

Investment	securities	were	$9.4	billion	and	$8.1	billion	on	
December	31,	2021	and	2020,	representing	11%	and	10%	
of	total	assets,	respectively.	See	Note	3	-	Investment	
Securities	for	more	information	about	the	securities	
portfolio.

The	following	table	presents	an	analysis	of	the	amortized	
cost,	remaining	contractual	maturities,	and	weighted-
average	yields	by	contractual	maturity	for	the	debt	
securities	portfolio.	

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Table	of	Contents

Table	7.7

CONTRACTUAL	MATURITIES	OF	INVESTMENT	SECURITIES

As	of	December	31,	2021

Within	1	year

After	1	year
Within	5	years

Amount

Yield	
(b)

Amount

Yield	
(b)

After	5	years
Within	10	years

Amount

Yield	
(b)

After 10 years

Amount

Yield	
(b)

$	

19	

	 1.33	 % $	

532	

	 1.64	 % $	 1,259	

	 1.45	 % $	

5,548	

	 1.53	 %

12	

	 2.88	

5	

	 0.69	

49	

	 2.04	

100	

	 0.69	

197	

	 1.41	

154	

	 1.41	

603	

	 1.64	

276	

	 2.30	

$	

36	

	 1.80	 % $	

681	

	 1.53	 % $	 1,610	

	 1.44	 % $	

6,427	

	 1.57	 %

—	

	 —	 % 	

—	

	 —	 % 	

—	

	 —	 % 	

712	

	 1.82	 %

$	

—	

	 —	 % $	

—	

	 —	 % $	

—	

	 —	 % $	

712	

	 1.82	 %

(Dollars	in	millions)

Securities	available	for	sale:

Government	agency	issued	
MBS	and	CMO	(a)

Other	U.S.	government	
agencies

States	and	municipalities

Total	securities	available	for	
sale

Securities	held	to	maturity:

Government	agency	issued	
MBS	and	CMO	(a)

Total	securities	held	to	
maturity

(a)	 Represents	government	agency-issued	mortgage-backed	securities	and	collateralized	mortgage	obligations	which,	when	adjusted	for	early	pay	downs,	

have	an	estimated	average	life	of	4.8	years.

(b)	 Weighted	average	yields	were	calculated	using	amortized	cost	on	a	fully-taxable	equivalent	basis,	assuming	a	25%	tax	rate	where	applicable.	

Loans and Leases

Period-end	loans	and	leases	decreased	$3.4	billion,	or	6%,	
to	$54.9	billion	as	of	December	31,	2021,	driven	by	a	$2.2	
billion	decrease	in	commercial	loans	primarily	tied	to	a	
$3.0	billion	decrease	in	PPP	loans,	offset	by	other	C&I	
growth,	and	a	$1.2	billion	decrease	in	consumer	loans.	
Average	loans	and	leases	increased	to	$56.3	billion	in	2021	
compared	to	$46.2	billion	in	2020	primarily	from	the	full	

Table	7.8

year	inclusion	of	acquired	IBKC	loans	in	2021,	offset	by	
declines	in	PPP	loans	and	other	consumer	real	estate	loan	
activity.

The	following	table	provides	detail	regarding	FHN's	loans	
and	leases:

(Dollars	in	millions)

2021

Percent
	of	total

2021		
Growth	
Rate

2020	(a)

Percent	
of	total	

2020	
Growth	
Rate	(a)

2019

Percent	
of	total

2019	
Growth	
Rate

	LOANS	AND	LEASES

Commercial:

Commercial,	financial,	
and	industrial	(b)

Commercial	real	estate

Total	commercial

Consumer:

Consumer	real	estate	

Credit	card	and	other

Total	consumer

$	

31,068	

	57	%

	(6)	% $	

33,104	

	57	%

	65	% $	

20,051	

	65	%

	21	%

12,109	

43,177	

10,772	

910	

11,682	

	22	

	79	

	20	

	1	

	21	

	(1)	

	(5)	

	(8)	

	(19)	

	(9)	

12,275	

45,379	

11,725	

1,128	

12,853	

	21	

	78	

	20	

	2	

	22	

	183	

	86	

	90	

	127	

	93	

4,337	

24,388	

6,177	

496	

6,673	

	14	

	79	

	20	

	1	

	21	

	8	

	19	

	(5)	

	(4)	

	(5)	

Total	loans	and	leases

$	

54,859	

	100	%

	(6)	% $	

58,232	

	100	%

	87	% $	

31,061	

	100	%

	13	%

(a)	 2020	includes	the	impact	of	balances	related	to	the	IBKC	merger	on	July	1,	2020	and	Truist	Bank	branch	acquisition	on	July	17,	2020.	
(b)	 Includes	equipment	financing	loans	and	leases.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

C&I	loans	are	the	largest	component	of	the	loan	and	lease	
portfolio,	comprising	57%	of	total	loans	and	leases	in	both	
2021	and	2020.	C&I	loans	decreased	6%,	or	$2.0	billion,	
from	2020	largely	driven	by	a	decrease	in	PPP	loans	and	
loans	to	mortgage	companies.	Excluding	PPP	loans,	C&I	
loans	increased	$978	million,	attributable	to	Regional	
Banking	growth.	Growth	in	other	specialty	lending	areas	
within	Specialty	Banking,	such	as	real	estate	rental	and	
leasing,	also	meaningfully	contributed	to	the	overall	
growth	in	non-PPP	C&I	loans	from	2020.	Commercial	real	

estate	loans	decreased	1%	to	$12.1	billion	in	2021,	
attributable	to	a	decline	in	Specialty	Banking	loans.	

Total	consumer	loans	decreased	9%,	or	$1.2	billion,	from	
the	end	of	2020,	largely	driven	by	paydowns	in	real	estate	
installment	loans	and	home	equity	lines	of	credit.

The	following	table	provides	detail	of	contractual	
maturities	at	December	31,	2021.

Table	7.9	

CONTRACTUAL	MATURITIES	OF	LOANS	AND	LEASES

(Dollars	in	millions)

Within	1	Year

After	1	Year
Within	5	
Years

After	5	Years	
Within	15	
Years

After	15	Years

Total

Commercial,	financial,	and	industrial

$	

8,174	 $	

15,095	 $	

7,023	 $	

776	 $	

Commercial	real	estate

Consumer	real	estate

Credit	card	and	other

			Total	loans	and	leases		

2,007	

93	

336	

6,939	

414	

428	

3,085	

1,706	

82	

78	

8,559	

64	

31,068	

12,109	

10,772	

910	

$	

10,610	 $	

22,876	 $	

11,896	 $	

9,477	 $	

54,859	

For	maturities	over	one	year	at	fixed	interest	rates:

Commercial,	financial,	and	industrial

$	

4,479	 $	

4,294	 $	

498	 $	

Commercial	real	estate

Consumer	real	estate

Credit	card	and	other

1,954	

297	

118	

1,103	

1,380	

74	

44	

3,076	

24	

9,271	

3,101	

4,753	

216	

Total	loans	and	leases	at	fixed	interest	rates

For	maturities	over	one	year	at	floating	interest	rates:

Commercial,	financial,	and	industrial

Commercial	real	estate

Consumer	real	estate

Credit	card	and	other

Total	loans	and	leases	at	floating	interest	rates

Total	maturities	over	one	year

$	

$	

$	

$	

Because	of	various	factors,	the	contractual	maturities	of	
consumer	loans	are	not	indicative	of	the	actual	lives	of	
such	loans.	A	significant	component	of	FHN’s	loan	
portfolio	consists	of	consumer	real	estate	loans,	a	majority	
of	which	are	home	equity	lines	of	credit	and	home	equity	
installment	loans.	These	loans	have	an	initial	period	where	
the	borrower	is	only	required	to	pay	the	periodic	interest.	
After	the	interest-only	period,	the	loan	will	require	the	
payment	of	both	principal	and	interest	over	the	remaining	
term.	Numerous	factors	can	contribute	to	the	actual	life	of	
a	home	equity	line	or	installment	loan.	As	a	result,	the	
actual	average	life	of	home	equity	lines	and	loans	is	
difficult	to	predict	and	changes	in	any	of	these	factors	
could	result	in	changes	in	projections	of	average	lives.	

6,848	 $	

6,851	 $	

3,642	 $	

17,341	

10,616	 $	

2,729	 $	

278	 $	

13,623	

4,985	

117	

310	

1,982	

326	

8	

34	

5,483	

40	

7,001	

5,926	

358	

16,028	 $	

5,045	 $	

5,835	 $	

26,908	

22,876	 $	

11,896	 $	

9,477	 $	

44,249	

Loans	Held	for	Sale

In	2020,	FHN	obtained	IBKC's	mortgage	banking	
operations	which	includes	origination	and	servicing	of	
residential	first	lien	mortgages	that	conform	to	standards	
established	by	GSEs	that	are	major	investors	in	U.S.	home	
mortgages	but	can	also	consist	of	junior	lien	and	jumbo	
loans	secured	by	residential	property.	These	loans	are	
primarily	sold	to	private	companies	that	are	unaffiliated	
with	the	GSEs	on	a	servicing-released	basis.	

The	legacy	FHN	loans	HFS	portfolio	consists	of	small	
business,	other	consumer	loans,	mortgage	warehouse,	
USDA,	student,	and	home	equity	loans.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

On	December	31,	2021,	loans	HFS	were	$1.2	billion,	a	
$150	million	increase	compared	to	December	31,	2020.	
On	an	average	basis,	HFS	loans	increased	to	$956	million	
in	2021	from	$835	million	in	2020,	generally	driven	by	the	
additional	volume	of	mortgage	loans	originated	with	the	

Asset Quality

Loan and Lease Portfolio Composition

FHN	groups	its	loans	into	portfolio	segments	based	on	
internal	classifications	reflecting	the	manner	in	which	the	
ALLL	is	established	and	how	credit	risk	is	measured,	
monitored,	and	reported.	From	time	to	time,	and	if	
conditions	are	such	that	certain	subsegments	are	uniquely	
affected	by	economic	or	market	conditions	or	are	
experiencing	greater	deterioration	than	other	

Underwriting Policies and Procedures

The	following	sections	describe	each	portfolio	as	well	as	
general	underwriting	procedures	for	each.	As	economic	
and	real	estate	conditions	develop,	enhancements	to	
underwriting	and	credit	policies	and	procedures	may	be	
necessary	or	desirable.	Loan	policies	and	procedures	for	
all	portfolios	are	reviewed	by	credit	risk	working	groups	
and	management	risk	committees	comprised	of	business	
line	managers	and	credit	administration	professionals	as	
well	as	by	various	other	reviewing	bodies	within	FHN.	
Policies	and	procedures	are	approved	by	key	executives	
and/or	senior	managers	leading	the	applicable	credit	risk	
working	groups	as	well	as	by	management	risk	
committees.	

Commercial Loan and Lease Portfolios

FHN’s	commercial	loan	approval	process	grants	lending	
authority	based	upon	job	description,	experience,	and	
performance.	The	lending	authority	is	delegated	to	the	
business	line	(Market	Managers,	Departmental	Managers,	
Regional	Presidents,	Relationship	Managers	(RM)	and	
Portfolio	Managers	(PM)	and	to	Credit	Risk	Managers.	
While	individual	limits	vary,	the	predominant	amount	of	
approval	authority	is	vested	with	the	Credit	Risk	
Management	function.	Portfolio,	industry,	and	borrower	
concentration	limits	for	the	various	portfolios	are	
established	by	executive	management	and	approved	by	
the	Executive	and	Risk	Committee	of	the	Board.

FHN’s	commercial	lending	process	incorporates	an	RM	
and	a	PM	for	most	commercial	credits.	The	RM	is	primarily	
responsible	for	communications	with	the	borrower	and	
maintaining	the	relationship,	while	the	PM	is	responsible	
for	assessing	the	credit	quality	of	the	borrower,	beginning	
with	the	initial	underwriting	and	continuing	through	the	
servicing	period.	Other	specialists	and	the	assigned	RM/
PM	are	organized	into	units	called	deal	teams.	Deal	teams	
are	constructed	with	specific	job	attributes	that	facilitate	

IBKC	merger.	Held-for-sale	consumer	mortgage	loans	
secured	by	residential	real	estate	in	process	of	foreclosure	
totaled	$3	million	and	$2	million	at	December	31,	2021	
and	2020,	respectively.

components	of	the	loan	portfolio,	management	may	
determine	the	ALLL	at	a	more	granular	level.	Commercial	
loans	are	composed	of	C&I	loans	and	CRE	loans.	Consumer	
loans	are	composed	of	consumer	real	estate	loans	and	
credit	card	and	other	loans.		

The	credit	risk	working	groups	and	management	risk	
committees	strive	to	ensure	that	the	approved	policies	
and	procedures	address	the	associated	risks	and	establish	
reasonable	underwriting	criteria	that	appropriately	
mitigate	risk.	Policies	and	procedures	are	reviewed,	
revised	and	re-issued	periodically	at	established	review	
dates	or	earlier	if	changes	in	the	economic	environment,	
portfolio	performance,	the	size	of	portfolio	or	industry	
concentrations,	or	regulatory	guidance	warrant	an	earlier	
review.	

FHN’s	ability	to	identify,	mitigate,	document,	and	manage	
ongoing	risk.	PMs	and	credit	analysts	provide	enhanced	
analytical	support	during	loan	origination	and	servicing,	
including	monitoring	of	the	financial	condition	of	the	
borrower	and	tracking	compliance	with	loan	agreements.	
Loan	closing	officers	and	the	construction	loan	
management	unit	specialize	in	loan	documentation	and	
the	management	of	the	construction	lending	process.	FHN	
strives	to	identify	problem	assets	early	through	
comprehensive	policies	and	guidelines,	targeted	portfolio	
reviews,	more	frequent	servicing	on	lower	rated	
borrowers,	and	an	emphasis	on	frequent	grading.	For	
smaller	commercial	credits,	generally	$5	million	or	less,	
and	income-producing	CRE	credits	greater	than	$10	
million	to	non-professional	real	estate	developers	and	
smaller	professional	real	estate	investors/developers,	FHN	
utilizes	a	centralized	underwriting	unit	in	order	to	
originate	and	grade	small	business	loans	more	efficiently	
and	consistently.

FHN	may	utilize	availability	of	guarantors/sponsors	to	
support	commercial	lending	decisions	during	the	credit	

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underwriting	process	and	when	determining	the	
assignment	of	internal	loan	grades.	Reliance	on	the	
guaranty	as	a	viable	secondary	source	of	repayment	is	a	
function	of	an	analysis	proving	capability	to	pay,	factoring	
in,	among	other	things,	liquidity	and	direct/indirect	cash	
flows.	FHN	also	considers	the	volume	and	amount	of	
guaranties	provided	for	all	global	indebtedness	and	the	
likelihood	of	realization.	FHN	presumes	a	guarantor’s	
willingness	to	perform	until	there	is	any	current	or	prior	
indication	or	future	expectation	that	the	guarantor	may	
not	willingly	and	voluntarily	perform	under	the	terms	of	
the	guaranty.	In	FHN’s	risk	grading	approach,	it	is	deemed	
that	financial	support	becomes	necessary	generally	at	a	
point	when	the	loan	would	otherwise	be	graded	
substandard,	reflecting	a	well-defined	weakness.	At	that	
point,	provided	willingness	and	capacity	to	support	are	
appropriately	demonstrated,	a	strong,	legally	enforceable	
guaranty	can	mitigate	the	risk	of	default	or	loss,	justify	a	
less	severe	rating,	and	consequently	reduce	the	level	of	
allowance	or	charge-off	that	might	otherwise	be	deemed	
appropriate.	

C&I

The	C&I	portfolio	totaled	$31.1	billion	as	of	December	31,	
2021	and	is	comprised	of	loans	used	for	general	business	
purposes.	Products	offered	in	the	C&I	portfolio	include	
term	loan	financing	of	owner-occupied	real	estate	and	
fixed	assets,	PPP	loans,	direct	financing	and	sales-type	
leases,	working	capital	lines	of	credit,	and	trade	credit	
enhancement	through	letters	of	credit.	

C&I	loans	are	underwritten	in	accordance	with	a	well-
defined	credit	origination	process.	This	process	includes	
applying	minimum	underwriting	standards	as	well	as	
separation	of	origination	and	credit	approval	roles	on	
transaction	sizes	over	PM	authorization	limits.	
Underwriting	typically	includes	due	diligence	of	the	
borrower	and	the	applicable	industry	of	the	borrower,	
analysis	of	the	borrower’s	available	financial	information,	
identification	and	analysis	of	the	various	sources	of	
repayment	and	identification	of	the	primary	risk	

attributes.	Stress	testing	the	borrower’s	financial	capacity,	
adherence	to	loan	documentation	requirements,	and	
assigning	credit	risk	grades	using	internally	developed	
scorecards	are	also	used	to	help	quantify	the	risk	when	
appropriate.	Underwriting	parameters	also	include	loan-
to-value	ratios	which	vary	depending	on	collateral	type,	
use	of	guaranties,	loan	agreement	requirements,	and	
other	recommended	terms	such	as	equity	requirements,	
amortization,	and	maturity.	Approval	decisions	also	
consider	various	financial	ratios	and	performance	
measures	of	the	borrowers,	such	as	cash	flow	and	balance	
sheet	leverage,	liquidity,	coverage	of	fixed	charges,	and	
working	capital.	Additionally,	approval	decisions	consider	
the	capital	structure	of	the	borrower,	sponsorship,	and	
quality/value	of	collateral.	Generally,	guideline	and	policy	
exceptions	are	identified	and	mitigated	during	the	
approval	process.	Pricing	of	C&I	loans	is	based	upon	the	
determined	credit	risk	specific	to	the	individual	borrower.	
Historically,	these	loans	typically	have	had	variable	rates	
tied	to	the	LIBOR	or	prime	rate	of	interest	plus	or	minus	
the	appropriate	margin.	However,	with	the	upcoming	
cessation	of	LIBOR,	FHN	no	longer	references	LIBOR	in	
new	loan	contracts,	and	the	existing	portfolio	of	loans	tied	
to	LIBOR	is	being	repriced	to	alternative	reference	rates.	

A	$3.0	billion	decrease	in	PPP	loans	drove	the	total	
decrease	from	December	31,	2020.	Excluding	PPP	loans,	
C&I	growth	was	$978	million,	or	3%.	The	largest	
geographical	concentrations	of	balances	as	of	
December	31,	2021	were	in	Tennessee	(20%),	Florida	
(12%),	Texas	(10%),	North	Carolina	(7%),	Louisiana	(7%),	
California	(7%),	and	Georgia	(5%),	with	no	other	state	
representing	more	than	5%	of	the	portfolio.

The	following	table	provides	the	composition	of	the	C&I	
portfolio	by	industry	as	of	December	31,	2021	and	2020.	
For	purposes	of	this	disclosure,	industries	are	determined	
based	on	the	NAICS	industry	codes	used	by	Federal	
statistical	agencies	in	classifying	business	establishments	
for	the	collection,	analysis,	and	publication	of	statistical	
data	related	to	the	U.S.	business	economy.	

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C&I	PORTFOLIO	BY	INDUSTRY	

December	31,	2021

December	31,	2020

Amount

Percent

Amount

Percent

Table	of	Contents

Table	7.10

(Dollars	in	millions)

Industry:

Loans	to	mortgage	companies

Finance	and	insurance

Real	estate	rental	&	leasing	(a)

Health	care	and	social	assistance

Accommodation	&	food	service

Manufacturing

Wholesale	trade
Retail	trade

$	

4,518	

3,483	

2,771	

2,413	

2,221	

1,950	

1,845	

1,532	

1,325	

9,010	

	15	% $	

	11	

	9	

	8	

	7	

	6	

	6	

	5	

	4	

	29	

5,404	

3,130	

2,365	

2,689	

2,303	

1,907	

2,079	

1,531	

1,686	

	16	%

	10	

	7	

	8	

	7	

	6	

	6	

	5	

	5	

10,010	

33,104	

	30	

	100	%

Energy
Other	(professional,	construction,	transportation,	etc)	(b)

Total	C&I	loan	portfolio

$	

31,068	

	100	% $	

(a) Leasing,	rental	of	real	estate,	equipment,	and	goods.
(b) Industries	in	this	category	each	comprise	less	than	5%	for	2021.

Industry	Concentrations

Loan	concentrations	are	considered	to	exist	for	a	financial	
institution	when	there	are	loans	to	numerous	borrowers	
engaged	in	similar	activities	that	would	cause	them	to	be	
similarly	impacted	by	economic	or	other	conditions.	Loans	
to	mortgage	companies	and	borrowers	in	the	finance	and	
insurance	industry	were	26%	of	FHN’s	C&I	loan	portfolio	
as	of	December	31,	2021,	and	as	a	result	could	be	affected	
by	items	that	uniquely	impact	the	financial	services	
industry.	Except	Loans	to	Mortgage	Companies	and	
Finance	and	Insurance,	as	discussed	below,	on	
December	31,	2021,	FHN	did	not	have	any	other	
concentrations	of	C&I	loans	in	any	single	industry	of	10%	
or	more	of	total	loans.

Loans	to	Mortgage	Companies

The	balance	of	loans	to	mortgage	companies	was	15%	of	
the	C&I	portfolio	as	of	December	31,	2021,	and	16%	of	the	
C&I	portfolio	as	of	December	31,	2020,	and	includes	
balances	related	to	both	home	purchase	and	refinance	
activity.	This	portfolio	generally	fluctuates	with	mortgage	
rates	and	seasonal	factors	and	includes	commercial	lines	
of	credit	to	qualified	mortgage	companies	primarily	for	
the	temporary	warehousing	of	eligible	mortgage	loans	
prior	to	the	borrower’s	sale	of	those	mortgage	loans	to	
third	party	investors.	Generally,	lending	to	mortgage	
lenders	increases	when	there	is	a	decline	in	mortgage	
rates	and	decreases	when	rates	rise.	The	decrease	in	loans	
to	mortgage	companies	year	over	year	was	due	to	existing	
home	supply	shortages,	construction	labor	and	materials	
shortages,	and	a	rise	in	mortgage	rates.	In	2021,	
approximately	48%	of	the	loans	funded	were	home	
purchases	and	52%	were	refinance	transactions.

Finance	and	Insurance

The	finance	and	insurance	component	represents	11%	of	
the	C&I	portfolio	as	of	December	31,	2021	compared	to	
10%	at	the	end	of	2020	and	includes	TRUPs	(i.e.,	long-term	
unsecured	loans	to	bank	and	insurance-related	
businesses),	loans	to	bank	holding	companies,	and	asset-
based	lending	to	consumer	finance	companies.	As	of	
December	31,	2021,	asset-based	lending	to	consumer	
finance	companies	represents	approximately	$1.4	billion	
of	the	finance	and	insurance	component.

Paycheck	Protection	Program	

In	2020,	Congress	created	the	Paycheck	Protection	
Program	(PPP)	in	response	to	the	economic	disruption	
associated	with	the	COVID-19	pandemic.	Under	the	PPP,	
qualifying	businesses	could	receive	loans	from	private	
lenders,	such	as	FHN,	that	are	fully	guaranteed	by	the	
Small	Business	Administration.	These	loans	potentially	are	
partly	or	fully	forgivable,	depending	upon	the	borrower’s	
use	of	the	funds	and	maintenance	of	employment	levels.	
To	the	extent	forgiven,	the	borrower	is	relieved	from	
payment	while	the	lender	is	still	paid	from	the	program.	

The	C&I	portfolio	as	of	December	31,	2021	included	8,372	
loans	made	under	the	PPP	with	an	aggregate	principal	
balance	of	$1.0	billion,	which	are	fully	government	
guaranteed	with	the	SBA.	Due	to	the	government	
guarantee	and	forgiveness	provisions,	PPP	loans	are	
considered	to	have	no	credit	risk	and	do	not	affect	the	
amount	of	provision	and	ALLL	recorded.	As	a	result,	no	
ALLL	was	recorded	for	PPP	loans	as	of	December	31,	2021,	
and	FHN	assigned	a	risk	weight	of	zero	to	PPP	loans	for	
regulatory	capital	purposes.	

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For	these	loans,	there	were	remaining	net	lender	fees	of	
approximately	$17	million	to	be	paid	to	FHN	as	of	
December	31,	2021.	During	2021,	FHN	continued	to	work	
with	its	clients	that	have	applied	for	and	received	PPP	loan	
forgiveness.	Through	December	31,	2021,	approximately	
$5	billion	of	the	original	$6	billion	in	PPP	loans	originated	
by	FHN	and	IBERIABANK	prior	to	acquisition	had	been	
forgiven	by	the	SBA.		

Commercial	Real	Estate

The	CRE	portfolio	totaled	$12.1	billion	as	of	December	31,	
2021,	a	$166	million,	or	1%,	decrease	compared	to	
December	31,	2020.		

The	CRE	portfolio	includes	both	financings	for	commercial	
construction	and	non-construction	loans.	This	portfolio	
contains	loans	and	draws	on	lines	and	letters	of	credit	for	
the	construction	and	mini-permanent	financing	of	income-
producing	real	estate.	

Residential	CRE	loans	include	loans	to	residential	builders	
and	developers	for	the	purpose	of	constructing	single-
family	homes,	condominiums,	and	town	homes,	and	on	a	
limited	basis,	for	developing	residential	subdivisions.	After	
the	fulfillment	of	existing	commitments	over	the	near	
term,	the	residential	CRE	class	will	be	in	a	wind-down	
state	with	the	expectation	of	full	runoff	in	the	foreseeable	
future.

Income-producing	CRE	loans	are	underwritten	in	
accordance	with	credit	policies	and	underwriting	
guidelines	that	are	reviewed	at	least	annually	and	revised	
as	necessary	based	on	market	conditions.	Loans	are	
underwritten	based	upon	project	type,	size,	location,	
sponsorship,	and	other	market-specific	data.	Generally,	
minimum	requirements	for	equity,	debt	service	coverage	
ratios,	and	level	of	pre-leasing	activity	are	established	
based	on	perceived	risk	in	each	subcategory.	Loan-to-
value	(value	is	defined	as	the	lower	of	cost	or	market)	
limits	are	set	below	regulatory	prescribed	ceilings	and	
generally	range	between	50%	and	80%	depending	on	the	
underlying	product	set.	Term	and	amortization	
requirements	are	set	based	on	prudent	standards	for	
interim	real	estate	lending.	Equity	requirements	are	
established	based	on	the	quality	and	liquidity	of	the	

Consumer Loan Portfolios

Consumer	Real	Estate

The	consumer	real	estate	portfolio	totaled	$10.8	billion	as	
of	December	31,	2021	and	is	primarily	composed	of	home	
equity	lines	and	installment	loans.	

The	largest	geographical	concentrations	of	balances	in	the	
consumer	real	estate	portfolio	as	of	December	31,	2021	
were	in	Florida	(32%),	Tennessee	(23%),	Louisiana	(10%),	
North	Carolina	(8%),	Texas	(7%),	and	New	York	(5%),	with	
no	other	state	representing	more	than	5%	of	the	portfolio.	

primary	source	of	repayment.	For	example,	more	equity	
would	be	required	for	a	speculative	construction	project	
or	land	loan	than	for	a	property	fully	leased	to	a	credit	
tenant	or	a	roster	of	tenants.	Typically,	a	borrower	must	
have	at	least	15%	of	cost	invested	in	a	project	before	FHN	
will	provide	loan	funding.	Income	properties	are	required	
to	achieve	a	debt	service	coverage	ratio	greater	than	or	
equal	to	125%	at	inception	or	stabilization	of	the	project	
based	on	loan	amortization	and	a	minimum	underwriting	
interest	rate.	Some	product	types	that	possess	a	greater	
risk	profile	require	a	higher	level	of	equity,	as	well	as	a	
higher	debt	service	coverage	ratio	threshold.	A	proprietary	
minimum	underwriting	interest	rate	is	used	to	calculate	
compliance	with	underwriting	standards.	Generally,	
specific	levels	of	pre-leasing	must	be	met	for	construction	
loans	on	income	properties.	A	global	cash	flow	analysis	is	
performed	at	the	sponsor	level.	The	majority	of	the	
portfolio	is	on	a	floating	rate	basis	tied	to	appropriate	
spreads	over	LIBOR.	However,	since	January	1,	2022,	no	
new	loan	contracts	reference	LIBOR,	and	the	existing	
portfolio	of	loans	tied	to	LIBOR	is	being	repriced	to	
alternative	reference	rates.	

The	credit	administration	and	ongoing	monitoring	consists	
of	multiple	internal	control	processes.	Construction	loans	
are	closed	by	a	centralized	control	unit	and	construction	
loan	management	is	administered	centrally	for	loans	$3	
million	and	over.	Underwriters	and	credit	approval	
personnel	stress	the	borrower’s/project’s	financial	
capacity	utilizing	numerous	attributes	such	as	interest	
rates,	vacancy,	and	discount	rates.	Key	information	is	
captured	from	the	various	portfolios	and	then	stressed	at	
the	aggregate	level.	Results	are	utilized	to	assist	with	the	
assessment	of	the	adequacy	of	the	ALLL	and	to	steer	
portfolio	management	strategies.

The	largest	geographical	concentrations	of	CRE	balances	
as	of	December	31,	2021	were	in	Florida	(26%),	Texas	
(12%),	North	Carolina	(11%),	Louisiana	(10%),	Tennessee	
(9%),	and	Georgia	(8%)	with	no	other	state	representing	
more	than	5%	of	the	portfolio.	Subcategories	of	income-
producing	CRE	loans	consist	of	multi-family	(25%),	office	
(24%),	retail	(19%),	industrial	(12%),	hospitality	(11%),	
land/land	development	(2%),	and	other	(7%).

As	of	December	31,	2021,	approximately	87%	of	the	
consumer	real	estate	portfolio	was	in	a	first	lien	position.	
As	of	December	31,	2021,	the	weighted	average	FICO	
score	at	origination	of	this	portfolio	was	755	and	the	
refreshed	FICO	scores	averaged	754,	no	significant	change	
from	FICO	scores	of	753	and	763,	respectively,	as	of	
December	31,	2020.	Generally,	performance	of	this	
portfolio	is	affected	by	life	events	that	affect	borrowers’	
finances,	the	level	of	unemployment,	and	home	prices.	

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As	of	December	31,	2021	and	2020,	FHN	had	held-to-
maturity	consumer	mortgage	loans	secured	by	real	estate	
totaling	$20	million	and	$36	million,	respectively,	that	
were	in	the	process	of	foreclosure.

HELOCs	comprised	$2.0	billion	and	$2.4	billion	of	the	
consumer	real	estate	portfolio	as	of	December	31,	2021	
and	December	31,	2020,	respectively.	FHN’s	HELOCs	
typically	have	a	5	or	10	year	draw	period	followed	by	a	10	
or	20	year	repayment	period,	respectively.	During	the	
draw	period,	a	borrower	is	able	to	draw	on	the	line	and	is	
only	required	to	make	interest	payments.	The	line	is	
frozen	if	a	borrower	becomes	past	due	on	payments.	Once	
the	draw	period	has	concluded,	the	line	is	closed	and	the	
borrower	is	required	to	make	both	principal	and	interest	
payments	monthly	until	the	loan	matures.	The	principal	
payment	generally	is	fully	amortizing,	but	payment	
amounts	will	adjust	when	variable	rates	reset	to	reflect	
changes	in	the	prime	rate.	

As	of	December	31,	2021,	approximately	88%	of	FHN's	
HELOCs	were	in	the	draw	period	compared	to	86%	at	the	

end	of	the	prior	year.	Based	on	when	draw	periods	are	
scheduled	to	end	per	the	line	agreement,	it	is	expected	
that	$431	million,	or	24%,	of	HELOCs	currently	in	the	draw	
period	will	enter	the	repayment	period	during	the	next	60	
months.	Generally,	delinquencies	for	HELOCs	that	have	
entered	the	repayment	period	are	initially	higher	than	
HELOCs	still	in	the	draw	period	because	of	the	increased	
minimum	payment	requirement;	however,	after	some	
seasoning,	performance	of	these	loans	usually	begins	to	
stabilize.	The	home	equity	lines	of	the	consumer	real	
estate	portfolio	are	monitored	closely	for	those	nearing	
the	end	of	the	draw	period	and	borrowers	are	initially	
contacted	at	least	6	months	before	the	repayment	period	
begins	to	remind	the	client	of	the	terms	of	their	
agreement	and	to	inform	them	of	options.	

The	following	table	shows	the	HELOCs	currently	in	the	
draw	period	and	expected	timing	of	conversion	to	the	
repayment	period.

Table	7.11

HELOC	DRAW	TO	REPAYMENT	SCHEDULE	

(Dollars	in	millions)

Months	remaining	in	draw	period:

0-12

13-24

25-36

37-48

49-60

>60

Total

December	31,	2021

December	31,	2020

Repayment
Amount

Percent

Repayment
Amount

Percent

$	

$	

43	

42	

50	

136	

160	

1,324	

1,755	

	2	% $	

	2	

	3	

	8	

	9	

	76	

	100	% $	

73	

66	

62	

67	

187	

1,662	

2,117	

	4	%

	3	

	3	

	3	

	8	

	79	

	100	%

Underwriting

For	the	majority	of	loans	in	this	portfolio,	underwriting	
decisions	are	made	through	a	centralized	loan	
underwriting	center.	To	obtain	a	consumer	real	estate	
loan,	the	loan	applicant(s)	in	most	cases	must	first	meet	a	
minimum	qualifying	FICO	score.	Minimum	FICO	score	
requirements	are	established	by	management	for	both	
loans	secured	by	real	estate	as	well	as	non-real	estate	
loans.	Management	also	establishes	maximum	loan	
amounts,	loan-to-value	ratios,	and	debt-to-income	ratios	
for	each	consumer	real	estate	product.	Applicants	must	
have	the	financial	capacity	(or	available	income)	to	service	
the	debt	by	not	exceeding	a	calculated	debt-to-income	
ratio.	The	amount	of	the	loan	is	limited	to	a	percentage	of	
the	lesser	of	the	current	appraised	value	or	sales	price	of	
the	collateral.	Identified	guideline	and	policy	exceptions	

require	established	mitigating	factors	that	have	been	
approved	for	use	by	Credit	Risk	Management.

HELOC	interest	rates	are	variable	and	adjust	with	
movements	in	the	index	rate	stated	in	the	loan	
agreement.	Such	loans	can	have	elevated	risks	of	default,	
particularly	in	a	rising	interest	rate	environment,	
potentially	stressing	borrower	capacity	to	repay	the	loan	
at	the	higher	interest	rate.	FHN’s	current	underwriting	
practice	requires	HELOC	borrowers	to	qualify	based	on	a	
sensitized	interest	rate	(above	the	current	note	rate),	fully	
amortized	payment	methodology.	FHN’s	underwriting	
guidelines	require	borrowers	to	qualify	at	an	interest	rate	
that	is	200	basis	points	above	the	note	rate.	This	mitigates	
risk	to	FHN	in	the	event	of	a	sharp	rise	in	interest	rates	
over	a	relatively	short	time	horizon.	

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Table	of	Contents

HELOC	Portfolio	Risk	Management

FHN	performs	continuous	HELOC	account	reviews	in	order	
to	identify	higher-risk	home	equity	lines	and	initiate	
preventative	and	corrective	actions.	The	reviews	consider	
a	number	of	account	activity	patterns	and	characteristics	
such	as	the	number	of	times	delinquent	within	recent	
periods,	changes	in	credit	bureau	score	since	origination,	
score	degradation,	performance	of	the	first	lien,	and	
account	utilization.	In	accordance	with	FHN’s	
interpretation	of	regulatory	guidance,	FHN	may	block	

Allowance for Credit Losses

The	ACL	is	maintained	at	a	level	sufficient	to	provide	
appropriate	reserves	to	absorb	estimated	future	credit	
losses	in	accordance	with	GAAP.	For	additional	
information	regarding	the	ACL,	see	Notes	1	and	5	of	this	
Report.

The	ALLL	was	$670	million	as	of	December	31,	2021,	or	
1.22%	of	total	loans	and	leases,	a	decrease	of	$293	million	

Consolidated Net Charge-offs

Net	charge-offs	were	$2	million	in	2021	compared	to	$120	
million	in	2020.	As	a	percentage	of	average	total	loans	and	
leases,	net	charge-offs	improved	26	basis	points	from	
2020.	

Net	charge-offs	in	the	C&I	portfolio	were	$13	million,	a	
decrease	of	$107	million	from	2020,	driven	by	lower	
energy-related	charge-offs	as	well	as	continued	
improvement	in	overall	asset	quality.		Net	charge-offs	in	

Table	7.12

future	draws	on	accounts	in	order	to	mitigate	risk	of	loss	
to	FHN.

Credit	Card	and	Other

The	credit	card	and	other	consumer	loan	portfolio,	which	
is	primarily	within	the	Regional	Banking	segment,	
decreased	$218	million	from	the	prior	year-end	to	$910	
million	as	of	December	31,	2021,	driven	by	net	
repayments	of	consumer	construction	loans.		

or	43	basis	points	from	the	end	of	2020,	reflecting	
improvement	in	the	macroeconomic	forecast,	positive	
credit	grade	migration,	and	lower	loan	balances.	The	ACL	
to	total	loans	and	leases	ratio	decreased	to	1.34%	as	of	
December	31,	2021	from	1.80%	as	of	December	31,	2020.	

the	commercial	real	estate	portfolio	were	minimal	in	both	
2021	and	2020.	

In	the	consumer	portfolio,	net	recoveries	of	$22	million	in	
consumer	real	estate	loans	were	offset	by	net	charge-offs	
of	$11	million	in	credit	card	and	other	loans.	Net	
recoveries	in	the	consumer	loan	portfolio	in	2020	were	$1	
million.		

ANALYSIS	OF	ALLOWANCE	FOR	CREDIT	LOSSES	AND	CHARGE-OFFS

(Dollars	in	millions)

Allowance	for	loan	and	lease	losses	

C&I

CRE

Consumer	real	estate

Credit	card	and	other

Total	allowance	for	loan	and	lease	losses

Reserve	for	remaining	unfunded	commitments

C&I

CRE

Consumer	real	estate

Credit	card	and	other
Total	reserve	for	remaining	unfunded	commitments	

Allowance	for	credit	losses

C&I

CRE

$	

$	

$	

$	

$	

2021

December	31
2020

2019

$	

$	

$	

$	

$	

334	

154	

163	

19	

670	

46	

12	

8	

—	
66	

380	

166	

$	

$	

$	

$	

$	

453	

242	

242	

26	

963	

65	

10	

10	

—	
85	

518	

252	

123	

36	

28	

13	

200	

4	

2	

—	

—	
6	

127	

38	

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Table	of	Contents

Consumer	real	estate

Credit	card	and	other

Total	allowance	for	credit	losses

Period-end	loans	and	leases

C&I

CRE

Consumer	real	estate	

Credit	card	and	other

$	

$	

171	

19	

736	

31,068	

12,109	

10,772	

910	

$	

$	

252	

26	

1,048	

$	

28	

13	

206	

33,104	

12,275	

11,725	

1,128	

$	

20,051	

4,337	

6,177	

496	

		Total	period-end	loans	and	leases

$	

54,859	

$	

58,232	

$	

31,061	

ALLL	/	loans	and	leases	%	

C&I

CRE

Consumer	real	estate

Credit	card	and	other

			Total	ALLL	/	loans	and	leases	%

ACL	/	loans	and	leases	%

C&I

CRE

Consumer	real	estate

Credit	card	and	other

			Total	ACL	/	loans	and	leases	%

Net	charge-offs	(recoveries)

C&I

CRE

Consumer	real	estate

Credit	card	and	other

			Total	net	charge-offs

Average	loans	and	leases	

C&I

CRE

Consumer	real	estate

Credit	card	and	other

	1.07	 %

	1.27	 %

	1.51	 %

	2.14	 %

	1.22	 %

	1.22	 %

	1.37	 %

	1.59	 %

	2.09	 %

	1.34	 %

13	

—	

(22)	

11	

2	

32,010	

12,314	

10,969	

1,005	

$	

$	

$	

	1.37	 %

	1.97	 %

	2.07	 %

	2.34	 %

	1.65	 %

	1.56	 %

	2.05	 %

	2.15	 %

	2.30	 %

	1.80	 %

120	

$	

1	

(10)	

9	

120	

$	

	0.62	 %

	0.83	 %

	0.45	 %

	2.68	 %

	0.64	 %

	0.63	 %

	0.88	 %

	0.45	 %

	2.62	 %

	0.66	 %

27	

1	

(12)	

11	

27	

27,638	

$	

18,283	

8,508	

9,191	

846	

4,102	

6,299	

505	

$	

$	

$	

			Total	average	loans	and	leases

$	

56,298	

$	

46,183	

$	

29,189	

Charge-off	%

C&I

CRE

Consumer	real	estate

Credit	card	and	other

			Total	charge-off	%

ALLL	/	net	charge-offs

C&I

CRE

Consumer	real	estate

	0.04	 %

	0.01	 %

NM

	1.05	 %

	—	 %

	2,645	 %

	13,189	 %

NM

	0.43	 %

	0.01	 %

NM

	1.04	 %

	0.26	 %

	376	 %

	43,670	 %

NM

	0.15	 %

	0.02	 %

NM

	2.25	 %

	0.09	 %

	453	 %

	5,213	 %

NM

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

	185	 %

	30,641	 %

	299	 %

	808	 %

	117	 %

	739	 %

Table	of	Contents

Credit	card	and	other

			Total	ALLL	/	net	charge-offs

NM	-	not	meaningful

Nonperforming Assets

Nonperforming	loans	are	loans	placed	on	nonaccrual	if	it	
becomes	evident	that	full	collection	of	principal	and	
interest	is	at	risk,	if	impairment	has	been	recognized	as	a	
partial	charge-off	of	principal	balance	due	to	insufficient	
collateral	value	and	past	due	status,	or	(on	a	case-by-case	
basis),	if	FHN	continues	to	receive	payments	but	there	are	
other	borrower-specific	issues.	Included	in	nonaccruals	
are	loans	on	which	FHN	continues	to	receive	payments,	
including	residential	real	estate	loans	where	the	borrower	
has	been	discharged	of	personal	obligation	through	
bankruptcy.	NPAs	consist	of	nonperforming	loans	and	
OREO	(excluding	OREO	from	government	insured	
mortgages).

Reflecting	an	overall	improvement	in	asset	quality,	total	
NPAs	(including	NPL	HFS)	decreased	$121	million	to	$285	
million	as	of	December	31,	2021,	and	the	ratio	of	
nonperforming	loans	to	total	loans	decreased	16	basis	
points	to	0.50%.		The	decrease	in	nonperforming	loans	
was	driven	primarily	by	the	CRE	and	consumer	real	estate	
portfolios.	

Certain	nonperforming	loans	in	both	the	commercial	and	
consumer	portfolios	are	deemed	collateral-dependent	and	
are	charged	down	to	an	estimate	of	collateral	value	less	
costs	to	sell.	Because	the	estimated	loss	has	been	
recognized	through	a	partial	charge-off,	typically	an	ALLL	is	
not	recorded.

Table	7.13

NONACCRUAL/NONPERFORMING	LOANS,	FORECLOSED	ASSETS,	&	OTHER	DISCLOSURES	(a)	(b)

(Dollars	in	millions)

Nonperforming	loans	and	leases

C&I

CRE

Consumer	real	estate

Credit	card	and	other

		Total	nonperforming	loans	and	leases	(c)	(d)	

Nonperforming	loans	held-for-sale	(d)

Foreclosed	real	estate	and	other	assets	(e)
Total	nonperforming	assets	(d)	(f)	

Nonperforming	loans	and	leases	to	total	loans	and	leases	

C&I

CRE

Consumer	real	estate

Credit	card	and	other

			Total	NPL	%

ALLL	/	NPLs
C&I
CRE

Consumer	real	estate

Credit	card	and	other

			Total	ALLL	/	NPLs

2021

December	31
2020

2019

$	

125	

$	

9	

138	

3	

275	

7	

3	
285	

$	

$	

$	

$	

$	

$	

144	

58	

182	

2	

386	

5	

15	
406	

$	

$	

$	

$	

	0.40	%

	0.08	%

	1.29	%

	0.31	%

	0.50	%

	268	%

	1,671	%

	118	%

	699	%

	244	%

	0.43	 %

	0.48	 %

	1.56	 %

	0.18	 %

	0.66	 %

	315	 %
	415	 %

	133	 %

	1313	 %

	249	 %

74	

2	

86	

—	

162	

4	

16	
182	

	0.37	 %

	0.04	 %

	1.39	 %

	0.07	 %

	0.52	 %

	166	 %
	1,973	 %

	33	 %

	3892	 %

	124	 %

(a) Balances	for	2019	do	not	include	PCI	loans	even	though	the	client	may	be	contractually	past	due.	PCI	loans	were	recorded	at	fair	value	upon	

acquisition	and	accreted	interest	income	over	the	remaining	life	of	the	loan.	PCI	loans	were	transitioned	to	PCD	status	upon	adoption	of	CECL.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

(b) Unless	otherwise	noted,	increases	in	balances	from	2019	to	2020	were	primarily	driven	by	acquired	nonperforming	assets.	
(c) Under	the	original	terms	of	the	loans,	estimated	interest	income	would	have	been	approximately	$19	million,	$18	million,	and	$11	million	

during	2021,	2020	and	2019,	respectively.

(d) Excludes	loans	and	leases	that	are	90	or	more	days	past	due	and	still	accruing	interest.
(e) Foreclosed	real	estate	from	GNMA	loans	totaled	$1	million,	$2	million,	and	$2	million	at	December	31,	2021,	2020,	and	2019,	respectively.	
(f) Balances	do	not	include	government-insured	foreclosed	real	estate.	Balances	for	2019	also	do	not	include	PCI	loans.	PCI	loans	were	

transitioned	to	PCD	status	upon	adoption	of	CECL.

The	following	table	provides	nonperforming	assets	by	
business	segment:

Table	7.14

NONPERFORMING	ASSETS	BY	SEGMENT

2021

December	31
2020

2019

(Dollars	in	millions)

Nonperforming	loans	and	leases	(a)	(b)

Regional	Banking

Specialty	Banking	

Corporate	
			Consolidated

Foreclosed	real	estate	(c)
Regional	Banking

Specialty	Banking	

Corporate	

			Consolidated

Nonperforming	Assets	(a)	(b)	(c)

Regional	Banking

Specialty	Banking	

Corporate	

			Consolidated

Nonperforming	loans	and	leases	to	total	loans	and	leases

Regional	Banking
Specialty	Banking	

Corporate	

			Consolidated

NPA	%	(d)

Regional	Banking

Specialty	Banking	

Corporate	

			Consolidated

$	

$	

$	

$	

$	

$	

163	

$	

78	

34	

275	

$	

2	

—	

1	

3	

$	

$	

165	

$	

78	

35	

278	

$	

	0.43	%
	0.48	

	5.39	

	0.50	%

	0.44	%

	0.48	

	5.51	

	0.51	%

216	

117	

53	
386	

$	

$	

12	

$	

1	

2	

15	

$	

228	

118	

55	

401	

$	

$	

	0.54	%
	0.68	

	5.70	

	0.66	%

	0.57	%

	0.68	

	5.87	

	0.69	%

45	

68	

49	
162	

12	

1	

3	

16	

57	

69	

52	

178	

	0.27	%
	0.51	

	5.22	

	0.52	%

	0.34	%

	0.52	

	5.48	

	0.57	%

(a) Excludes	loans	and	leases	that	are	90	or	more	days	past	due	and	still	accruing	interest.
(b) Excludes	loans	classified	as	held	for	sale.
(c) Excludes	foreclosed	real	estate	and	receivables	related	to	government-insured	mortgages	of	$1	million,	$5	million,	and	$10	million	as	of	December	31,	

2021,	2020,	and	2019,	respectively.

(d) Ratio	is	non-performing	assets	related	to	the	loan	and	lease	portfolio	to	total	loans	plus	foreclosed	real	estate	and	other	assets.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

Lending Assistance for Borrowers 

In	addition	to	PPP	loans,	other	customer	support	
initiatives	in	response	to	the	COVID-19	pandemic	include	
incremental	lending	assistance	for	borrowers	through	
delayed	payment	programs	and	fee	waivers.

The	following	table	provides	the	UPB	of	loans	related	to	
deferrals	granted	to	FHN’s	customers	as	of	December	31,	
2021	and	December	31,	2020.

Table	7.15

(Dollars	in	millions)

Commercial:

C&I

CRE

Total	Commercial

Consumer:

HELOC

Real	estate	installment	loans

Credit	card	and	other

Total	Consumer

Total

CUSTOMER	DEFERRALS

December	31,	
2021

December	31,	
2020

$	

$	

$	

$	

$	

9	 $	

26	

35	 $	

5	 $	

44	

—	

49	 $	

84	 $	

104	

194	

298	

14	

202	

4	

220	

518	

Commercial	deferrals	as	of	December	31,	2021	were	
comprised	primarily	of	private	client	(59%	or	$21	million)	
and	general	commercial	(40%	or	$14	million).	

deferral,	they	were	excluded	from	loans	past	due	30	to	89	
days	and	loans	past	due	90	days	or	more	in	the	table	and	
discussion	below.

To	the	extent	that	loans	were	past	due	as	of	December	31,	
2021	or	December	31,	2020	and	had	been	granted	a	

Past Due Loans and Potential Problem Assets

Past	due	loans	are	loans	contractually	past	due	as	to	
interest	or	principal	payments,	but	which	have	not	yet	
been	put	on	nonaccrual	status.	Loans	90	days	or	more	
past	due	and	still	accruing	were	$40	million	as	of	
December	31,	2021,	an	increase	of	$23	million	compared	
to	December	31,	2020,	primarily	from	consumer	real	
estate	loans.	Loans	30	to	89	days	past	due	increased	$8	

million	from	year-end	2020	to	$108	million	as	of	
December	31,	2021,	as	a	higher	level	of	C&I	loans	past	due	
were	offset	by	lower	consumer	real	estate	loans	past	due	
less	than	90	days,	most	notably	in	the	CRE	and	consumer	
real	estate	portfolios.

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Table	of	Contents

	Table	7.16

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

ACCRUING	DELINQUENCIES	&	OTHER	CREDIT	DISCLOSURES	

(Dollars	in	millions)

Accruing	loans	and	leases	30+	days	past	due	

C&I

CRE

Consumer	real	estate	

Credit	card	and	other

			Total	accruing	loans	and	leases	30+	days	past	due	

Accruing	loans	and	leases	30+	days	past	due	%	

C&I

CRE
Consumer	real	estate

Credit	card	and	other

			Total	accruing	loans	and	leases	30+	days	past	due	%

Accruing	loans	and	leases	90+	days	past	due	(a)	(b)	(c)

C&I

CRE

Consumer	real	estate

Credit	card	and	other

Total	accruing	loans	and	leases	90+	days	past	due	

Loans	held	for	sale

30	to	89	days	past	due	(b)

30	to	89	days	past	due	-	guaranteed	portion	(b)	(d)

90+	days	past	due	(b)

90+	days	past	due	-	guaranteed	portion	(b)	(d)

$	

$	

$	

$	

$	

2021

December	31
2020

2019

$	

58	

13	

70	

7	

$	

15	

23	

69	

10	

148	

$	

117	

$	

	0.19	%

	0.11	
	0.65	

	0.76	

	0.27	%

	0.05	%

	0.19	
	0.58	

	0.87	

	0.20	%

$	

$	

$	

5	

—	

33	

2	

40	

7	

2	

24	

12	

$	

$	

$	

—	

—	

16	

1	

17	

6	

5	

12	

10	

9	

1	

43	

5	

58	

	0.05	%

	0.02	
	0.70	

	0.93	

	0.19	%

2	

—	

18	

2	

22	

4	

3	

6	

6	

(a) Excludes	loans	classified	as	held	for	sale.
(b) Amounts	are	not	included	in	nonperforming/nonaccrual	loans.
(c) Amounts	are	also	included	in	accruing	loans	and	leases	30+	days	past	due.
(d) Guaranteed	loans	include	FHA,	VA,	and	GNMA	loans	repurchased	through	the	GNMA	buyout	program.

Potential	problem	assets	represent	those	assets	where	
information	about	possible	credit	problems	of	borrowers	
has	caused	management	to	have	serious	doubts	about	the	
borrower’s	ability	to	comply	with	present	repayment	
terms	and	includes	loans	past	due	90	days	or	more	and	
still	accruing.	This	definition	is	believed	to	be	substantially	
consistent	with	the	standards	established	by	the	Federal	
banking	regulators	for	loans	classified	as	substandard.	At	

year-end	2021,	potential	problem	assets	in	the	loan	
portfolio	decreased	$121	million	from	December	31,	2020	
to	$597	million	on	December	31,	2021.	The	decrease	was	
attributable	to	an	overall	improvement	in	asset	quality.	
The	current	expectation	of	losses	from	potential	problem	
assets	has	been	included	in	management’s	analysis	for	
assessing	the	adequacy	of	the	allowance	for	loan	and	
lease	losses.

Troubled Debt Restructuring and Loan Modifications

As	part	of	FHN’s	ongoing	risk	management	practices,	FHN	
attempts	to	work	with	borrowers	when	appropriate	to	
extend	or	modify	loan	terms	to	better	align	with	their	
current	ability	to	repay.	Extensions	and	modifications	to	
loans	are	made	in	accordance	with	internal	policies	and	
guidelines	which	conform	to	regulatory	guidance.	Each	
occurrence	is	unique	to	the	borrower	and	is	evaluated	

separately.	In	a	situation	where	an	economic	concession	
has	been	granted	to	a	borrower	that	is	experiencing	
financial	difficulty,	FHN	identifies	and	reports	that	loan	as	
a	TDR.	

For	loan	modifications	that	were	made	during	2021	and	
2020	that	met	the	TDR	relief	provisions	outlined	in	either	
the	CARES	Act,	as	extended	by	the	CAA,	or	revised	

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Interagency	Guidance,	FHN	has	excluded	these	
modifications	from	consideration	as	a	TDR,	and	has	
excluded	loans	with	these	qualifying	modifications	from	
designation	as	a	TDR	in	the	information	and	discussion	
that	follows.	See	Note	1	-	Significant	Accounting	Policies	
and	Note	4	–	Loans	and	Leases	for	further	discussion	
regarding	TDRs	and	loan	modifications.

Commercial	Loan	Modifications

As	part	of	FHN’s	credit	risk	management	governance	
processes,	the	Loan	Rehab	and	Recovery	Department	
(LRRD)	is	responsible	for	managing	most	commercial	
relationships	with	borrowers	whose	financial	condition	
has	deteriorated	to	such	an	extent	that	the	credits	are	
being	considered	for	impairment,	classified	as	
substandard	or	worse,	placed	on	nonaccrual	status,	
foreclosed	or	in	process	of	foreclosure,	or	in	active	or	
contemplated	litigation.	LRRD	has	the	authority	and	
responsibility	to	enter	into	workout	and/or	rehabilitation	
agreements	with	troubled	commercial	borrowers	in	order	
to	mitigate	and/or	minimize	the	amount	of	credit	losses	
recognized	from	these	problem	assets.	While	every	
circumstance	is	different,	LRRD	will	generally	use	
forbearance	agreements	(generally	6-12	months)	as	an	
element	of	commercial	loan	workouts,	which	might	
include	reduced	interest	rates,	reduced	payments,	release	
of	guarantor,	or	entering	into	short	sale	agreements.

The	individual	impairment	assessments	completed	on	
commercial	loans	in	accordance	with	the	Accounting	
Standards	Codification	Topic	related	to	Troubled	Debt	
Restructurings	(“ASC	310-40”)	include	loans	classified	as	
TDRs	as	well	as	loans	that	may	have	been	modified	yet	not	
classified	as	TDRs	by	management.	For	example,	a	
modification	of	loan	terms	that	management	would	
generally	not	consider	to	be	a	TDR	could	be	a	temporary	
extension	of	maturity	to	allow	a	borrower	to	complete	an	
asset	sale	whereby	the	proceeds	of	such	transaction	are	to	
be	paid	to	satisfy	the	outstanding	debt.	Additionally,	a	
modification	that	extends	the	term	of	a	loan	but	does	not	
involve	reduction	of	principal	or	accrued	interest,	in	which	
the	interest	rate	is	adjusted	to	reflect	current	market	rates	
for	similarly	situated	borrowers,	is	not	considered	a	TDR.	
Nevertheless,	each	assessment	will	take	into	account	any	
modified	terms	and	will	be	comprehensive	to	ensure	
appropriate	impairment	assessment.	If	individual	
impairment	is	identified,	management	will	either	hold	
specific	reserves	on	the	amount	of	impairment,	or,	if	the	
loan	is	collateral	dependent,	write	down	the	carrying	
amount	of	the	asset	to	the	net	realizable	value	of	the	
collateral.

Consumer	Loan	Modifications

FHN	does	not	currently	participate	in	any	of	the	loan	
modification	programs	sponsored	by	the	U.S.	government	
but	does	generally	structure	modified	consumer	loans	
using	the	parameters	of	the	former	Home	Affordable	
Modification	Program.	Generally,	a	majority	of	loans	

modified	under	any	such	proprietary	programs	are	
classified	as	TDRs.	

Within	the	HELOC	and	real	estate	installment	loans	classes	
of	the	consumer	portfolio	segment,	TDRs	are	typically	
modified	by	reducing	the	interest	rate	(in	increments	of	25	
basis	points	to	a	minimum	of	1%	for	up	to	5	years)	and	a	
possible	maturity	date	extension	to	reach	an	affordable	
housing	debt-to-income	ratio.	After	5	years,	the	interest	
rate	generally	returns	to	the	original	interest	rate	prior	to	
modification;	for	certain	modifications,	the	modified	
interest	rate	increases	2%	per	year	until	the	original	
interest	rate	prior	to	modification	is	achieved.	Permanent	
mortgage	TDRs	are	typically	modified	by	reducing	the	
interest	rate	(in	increments	of	25	basis	points	to	a	
minimum	of	2%	for	up	to	5	years)	and	a	possible	maturity	
date	extension	to	reach	an	affordable	housing	debt-to-
income	ratio.	After	5	years,	the	interest	rate	steps	up	1	
percent	every	year	until	it	reaches	the	Federal	Home	Loan	
Mortgage	Corporation	Weekly	Survey	Rate	cap.	
Contractual	maturities	may	be	extended	to	40	years	on	
permanent	mortgages	and	to	30	years	for	consumer	real	
estate	loans.	Within	the	credit	card	class	of	the	consumer	
portfolio	segment,	TDRs	are	typically	modified	through	
either	a	short-term	credit	card	hardship	program	or	a	
longer-term	credit	card	workout	program.	In	the	credit	
card	hardship	program,	borrowers	may	be	granted	rate	
and	payment	reductions	for	6	months	to	1	year.	In	the	
credit	card	workout	program,	clients	are	granted	a	rate	
reduction	to	0%	and	term	extensions	for	up	to	5	years	to	
pay	off	the	remaining	balance.

Following	classification	as	a	TDR,	modified	loans	within	the	
consumer	portfolio,	which	were	previously	evaluated	for	
impairment	on	a	collective	basis	determined	by	their	
smaller	balances	and	homogenous	nature,	become	
subject	to	the	impairment	guidance	in	ASC	310-10-35,	
which	requires	individual	evaluation	of	the	debt	for	
impairment.	However,	as	applicable	accounting	guidance	
allows,	FHN	may	aggregate	certain	smaller-balance	
homogeneous	TDRs	and	use	historical	statistics,	such	as	
aggregated	charge-off	amounts	and	average	amounts	
recovered,	along	with	a	composite	effective	interest	rate	
to	measure	impairment	when	such	impaired	loans	have	
risk	characteristics	in	common.

FHN	had	$206	million	and	$307	million	portfolio	loans	
classified	as	held-for-investment	TDRs	on	December	31,	
2021	and	2020,	respectively,	a	decrease	of	$101	million	
between	periods.		For	these	TDRs,	including	specific	
reserves,	FHN	had	an	allowance	for	loan	and	lease	losses	
of	$12	million	and	$15	million,	or	6%	and	5%	of	TDR	
balances,	as	of	December	31,	2021	and	2020,	respectively.	
Additionally,	FHN	had	$35	million	and	$42	million	of	HFS	
loans	classified	as	TDRs	at	year-end	2021	and	2020,	
respectively.	

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The	following	table	provides	a	summary	of	TDRs	for	the	
periods	ended	December	31,	2021	and	2020.		

TROUBLED	DEBT	RESTRUCTURINGS	

December	31,	2021

December	31,	2020

Table	7.17

(Dollars	in	millions)
Held	for	investment:
Commercial	loans:

Current

Delinquent

Non-accrual

									Total	commercial	loans

Consumer	real	estate:

Current

Delinquent

Non-accrual	(a)

									Total	consumer	real	estate

Credit	card	and	other:

Current

Delinquent

Non-accrual

									Total	credit	card	and	other

Total	held	for	investment

Held	for	sale:
Current

Delinquent

Non-accrual

Total	held	for	sale

Total	troubled	debt	restructurings

$	

$	

$	

$	

$	

53	 $	
—	

35	

88	

60	 $	

4	

53	

117	

1	

—	

—	

1	
206	 $	

27	 $	

7	

1	

35	

241	 $	

82	

—	

84	

166	

77	
2	

61	

140	

1	

—	

—	

1	

307	

36	

5	

1	

42	

349	

(a) Balances	as	of	December	31,	2021	and	2020,	include	$12	million	and	$11	million,	respectively,	of	discharged	

bankruptcies.

Deposits

Total	deposits	were	$74.9	billion	as	of	December	31,	2021,	
up	$4.9	billion	from	$70.0	billion	as	of	December	31,	2020,	
driven	by	a	$5.7	billion	increase	in	non-interest	bearing	
deposits	as	a	result	of	elevated	liquidity	tied	to	
government	stimulus	associated	with	the	COVID-19	
pandemic.	Growth	in	noninterest-bearing	deposits	was	
partially	offset	by	a	$1.6	billion	decline	in	time	deposits.	

The	following	tables	summarize	FHN's	total	deposits	and	
estimated	uninsured	total	deposits	for	2021,	2020,	and	
2019,	as	well	as	the	maturities	of	FHN's	uninsured	time	
deposits	as	of	December	31,	2021.	See	Table	7.2	-	Average	
Balances,	Net	Interest	Income	and	Yields/Rates	in	this	
Report	for	information	on	average	deposits	including	
average	rates	paid.

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Table	7.18

DEPOSITS

(Dollars	in	millions)

Savings

Time	deposits

Other	interest-bearing	deposits

Total	interest-bearing	deposits

Noninterest-bearing	deposits

2021

Percent	
of	Total

2021	
Growth	
Rate

2020

Percent	
of	Total

2020	
Growth		
Rate

2019

Percent
	of	Total

2019	
Growth
	Rate

$	 26,457	

	35	%

	(3)	% $	

27,324	

	39	%

	134	% $	

11,665	

	36	%

	(3)	%

3,500	

17,055	

47,012	

27,883	

	5	

	23	

	63	

	37	

	(31)	

	11	

	(2)	

	26	

5,070	

15,415	

47,809	

22,173	

	7	

	22	

	68	

	32	

	40	

	77	

	99	

	163	

3,618	

8,718	

24,001	

8,429	

	11	

	27	

	74	

	26	

	(12)	

	4	

	(2)	

	4	

Total	deposits

$	 74,895	

	100	%

	7	% $	

69,982	

	100	%

	116	% $	

32,430	

	100	%

	(1)	%

	Table	7.19

UNINSURED	DEPOSITS

For	the	Year	Ended	December	31,

(Dollars	in	millions)

2021

2020

2019

Uninsured	deposits

$	

39,756	 $	

33,057	 $	

12,176	

	Table	7.20	

UNINSURED	TIME	DEPOSITS	BY	MATURITY

(Dollars	in	millions)

December	31,	2021

Portion	of	U.S.	time	deposits	in	excess	of	insurance	limit

$	

Time	deposits	otherwise	uninsured	with	a	maturity	of:

3	months	or	less

Over	3	months	through	6	months

Over	6	months	through	12	months

Over	12	months

515	

212	

117	

124	

62	

Short-Term Borrowings

Short-term	borrowings	include	federal	funds	purchased,	
securities	sold	under	agreements	to	repurchase,	trading	
liabilities,	and	other	short-term	borrowings.	Total	short-
term	borrowings	were	$2.6	billion	as	of	December	31,	
2021	and	December	31,	2020.

Short-term	borrowings	balances	fluctuate	largely	based	on	
the	level	of	FHLB	borrowing	as	a	result	of	loan	demand,	
deposit	levels	and	balance	sheet	funding	strategies.	
Trading	liabilities	fluctuate	based	on	various	factors,	

Term Borrowings

including	levels	of	trading	securities	and	hedging	
strategies.	Federal	funds	purchased	fluctuates	depending	
on	the	amount	of	excess	funding	of	FHN's	correspondent	
bank	customers.	Balances	of	securities	sold	under	
agreements	to	repurchase	fluctuate	based	on	cost	
attractiveness	relative	to	FHLB	borrowing	levels	and	the	
ability	to	pledge	securities	toward	such	transactions.	See	
Note	10	-	Short-Term	Borrowings	for	additional	
information.	

Term	borrowings	include	senior	and	subordinated	
borrowings	with	original	maturities	greater	than	one	year.	
Total	term	borrowings	were	$1.6	billion	on	December	31,	
2021,	an	$80	million	decrease	from	$1.7	billion	on	
December	31,	2020.	

During	2021,	FHN	redeemed	$94	million	of	legacy	IBKC	
junior	subordinated	debt	underlying	multiple	issuances	of	
trust	preferred	securities.	The	redemption	resulted	in	a	
loss	on	debt	extinguishment	of	$26	million.	See	Note	11	-	
Term	Borrowings	for	additional	information.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Table	of	Contents

Capital 

Management’s	objectives	are	to	provide	capital	sufficient	
to	cover	the	risks	inherent	in	FHN’s	businesses,	to	
maintain	excess	capital	to	well-capitalized	standards,	and	
to	assure	ready	access	to	the	capital	markets.	

Total	equity	increased	$187	million	to	$8.5	billion	on	
December	31,	2021	from	$8.3	billion	on	December	31,	
2020.	Significant	changes	included	net	income	of	$1.0	
billion	and	the	issuance	of	$145	million	in	Series	F	
preferred	stock,	which	were	offset	by	$416	million	in	

common	share	repurchases,	$364	million	in	common	and	
preferred	dividends,	a	$148	decrease	in	AOCI,	and	$100	
million	from	the	call	of	Series	A	preferred	stock.	

The	following	tables	provide	a	reconciliation	of	
shareholders’	equity	from	the	Consolidated	Balance	
Sheets	to	Common	Equity	Tier	1,	Tier	1	and	Total	
Regulatory	Capital	as	well	as	certain	selected	capital	
ratios:

Table	7.21a

(Dollars	in	millions)

FHN	shareholders’	equity

REGULATORY	CAPITAL	DATA

Modified	CECL	transitional	amount	(a)
FHN	non-cumulative	perpetual	preferred

Common	equity	tier	1	before	regulatory	adjustments	

Regulatory	adjustments:

Disallowed	goodwill	and	other	intangibles

Net	unrealized	(gains)	losses	on	securities	available	for	sale

Net	unrealized	(gains)	losses	on	pension	and	other	postretirement	plans

Net	unrealized	(gains)	losses	on	cash	flow	hedges

Disallowed	deferred	tax	assets

Other	deductions	from	common	equity	tier	1

Common	equity	tier	1

FHN	non-cumulative	perpetual	preferred	(b)	

Qualifying	noncontrolling	interest—First	Horizon	Bank	preferred	stock

Tier	1	capital

Tier	2	capital

Total	regulatory	capital

Risk-Weighted	Assets

First	Horizon	Corporation

First	Horizon	Bank

Average	Assets	for	Leverage
First	Horizon	Corporation

First	Horizon	Bank

$	

$	

$	

$	

$	

$	

December	31,	
2021

December	31,	
2020

8,199	 $	
114	
(520)	
7,793	 $	

8,012	

191	
(470)	
7,733	

(1,711)	

(1,757)	

36	

255	

(3)	

(2)	

(1)	
6,367	 $	
426	

295	
7,088	 $	
830	
7,918	 $	

64,183	 $	
63,601	

87,683	

86,953	

(108)	

260	

(12)	

(5)	

(1)	

6,110	

377	

295	

6,782	

1,153	

7,935	

63,140	

62,508	

82,347	

81,709	

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Table	of	Contents

Table	7.21b

(Dollars	in	millions)
Common	Equity	Tier	1

First	Horizon	Corporation

First	Horizon	Bank

Tier	1

First	Horizon	Corporation

First	Horizon	Bank

Total

First	Horizon	Corporation

First	Horizon	Bank

Tier	1	Leverage

First	Horizon	Corporation

First	Horizon	Bank

Other	Capital	Ratios	

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

REGULATORY	RATIOS	&	AMOUNTS

December	31,	2021
Amount
Ratio

December	31,	2020
Amount
Ratio

	9.92	% $	

6,367	

	9.68	% $	

	 10.75	

6,838	

	 10.46	

	11.04	

	 11.22	

	12.34	

	 12.41	

	8.08	
8.20	

9.53	

6.73	

9.20	

7,088	

	10.74	

7,133	

	 10.93	

7,918	

	12.57	

7,893	

	 12.52	

7,088	
7,133	

	8.24	
8.36	

9.86	

6.89	

8.82	

6,110	

6,537	

6,782	

6,832	

7,935	

7,827	

6,782	
6,832	

Total	period-end	equity	to	period-end	assets	

Tangible	common	equity	to	tangible	assets	(c)

Adjusted	tangible	common	equity	to	risk	weighted	assets	(c)

(a)	 The	modified	CECL	transitional	amount	is	calculated	as	defined	in	the	final	rule	issued	by	the	banking	regulators	on	August	26,	2020	and	includes	the	full	
amount	of	the	impact	to	retained	earnings	from	the	initial	adoption	of	CECL	plus	25%	of	the	change	in	the	adjusted	allowance	for	credit	losses	since	
FHN’s	initial	adoption	of	CECL	through	December	31,	2021.

(b)	 The	$94	million	carrying	value	of	the	Series	D	preferred	stock	does	not	qualify	as	Tier	1	capital	because	the	earliest	redemption	date	is	less	than	five	years	

from	the	issuance	date.	

(c)	 Tangible	common	equity	to	tangible	assets	and	adjusted	tangible	common	equity	to	risk-weighted	assets	are	non-GAAP	measures	and	are	reconciled	to	

total	equity	to	total	assets	(GAAP)	in	the	Non-GAAP	to	GAAP	Reconciliation	-	Table	7.30.

Banking	regulators	define	minimum	capital	ratios	for	bank	
holding	companies	and	their	bank	subsidiaries.	Based	on	
the	capital	rules	and	definitions	prescribed	by	the	banking	
regulators,	should	any	depository	institution’s	capital	
ratios	decline	below	predetermined	levels,	it	would	
become	subject	to	a	series	of	increasingly	restrictive	
regulatory	actions.	The	system	categorizes	a	depository	
institution’s	capital	position	into	one	of	five	categories	
ranging	from	well-capitalized	to	critically	under-
capitalized.	For	an	institution	the	size	of	FHN	to	qualify	as	
well-capitalized,	Common	Equity	Tier	1,	Tier	1	Capital,	
Total	Capital,	and	Leverage	capital	ratios	must	be	at	least	
6.50%,	8.00%,	10.00%,	and	5.00%,	respectively.	
Furthermore,	a	capital	conservation	buffer	of	50	basis	
points	above	these	levels	must	be	maintained	on	the	
Common	Equity	Tier	1,	Tier	1	Capital	and	Total	Capital	
ratios	to	avoid	restrictions	on	dividends,	share	
repurchases	and	certain	discretionary	bonuses.	As	of	
December	31,	2021,	both	FHN	and	First	Horizon	Bank	had	
sufficient	capital	to	qualify	as	well-capitalized	institutions	
and	to	meet	the	capital	conservation	buffer	requirement.	
Capital	ratios	for	both	FHN	and	First	Horizon	Bank	as	of	

Stress Testing 

The	Economic	Growth,	Regulatory	Relief,	and	Consumer	
Protection	Act,	along	with	an	interagency	regulatory	
statement	effectively	exempted	both	FHN	and	First	

December	31,	2021	are	calculated	under	the	final	rule	
issued	by	the	banking	regulators	in	late	August	2020	to	
delay	the	effects	of	CECL	on	regulatory	capital	for	two	
years,	followed	by	a	three-year	transition	period.

For	both	FHN	and	First	Horizon	Bank,	the	risk-based	
regulatory	capital	ratios	increased	in	2021	relative	to	2020	
primarily	from	the	net	positive	impact	of	net	income	less	
dividends	and	share	repurchases.	FHN's	Tier	1	Capital	ratio	
further	benefited	from	the	issuance	in	2021	of	its	Series	F	
preferred	stock,	partially	offset	by	the	retirement	of	its	
Series	A	preferred	stock.	FHN's	Total	Capital	ratio	as	of	
December	31,	2021	was	unfavorably	impacted	by	the	
retirement	of	legacy	IBKC	trust	preferred	securities,	which	
qualified	as	Tier	2	capital.	The	Tier	1	Leverage	ratio	for	
both	FHN	and	First	Horizon	Bank	decreased	from	
December	31,	2020	as	a	result	of	an	increase	in	average	
assets.		

During	2022,	capital	ratios	are	expected	to	remain	above	
well-capitalized	standards	plus	the	required	capital	
conservation	buffer.	

Horizon	Bank	from	Dodd-Frank	Act	stress	testing	
requirements	starting	in	2018.	

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For	2021,	FHN	and	First	Horizon	Bank	completed	a	
company	run	stress	test	using	the	Comprehensive	Capital	
Analysis	and	Review	(CCAR)	Resubmission	scenarios	
published	in	February	2021.	Results	of	these	tests	indicate	
that	both	FHN	and	First	Horizon	Bank	would	be	able	to	
maintain	capital	well	in	excess	of	Basel	III	Adequately	
Capitalized	standards	under	the	hypothetical	severe	global	
recession	of	the	2021	CCAR	Resubmission	Severely	
Adverse	scenario.	A	summary	of	those	results	was	posted	
in	the	“News	&	Events-Stress	Testing	Results”	section	on	
FHN’s	investor	relations	website	on	June	28,	2021.	Neither	
FHN’s	stress	test	posting,	nor	any	other	material	found	on	

Common Stock Purchase Programs 

Pursuant	to	Board	authority,	FHN	may	repurchase	shares	
of	its	common	stock	from	time	to	time	and	will	evaluate	
the	level	of	capital	and	take	action	designed	to	generate	
or	use	capital,	as	appropriate,	for	the	interests	of	the	
shareholders,	subject	to	legal	and	regulatory	restrictions.		
FHN’s	Board	has	not	authorized	a	preferred	stock	
purchase	program.	

General	Purchase	Program

On	January	23,	2018,	FHN	announced	a	$250	million	share	
purchase	authority	with	an	expiration	date	of	January	31,	
2020.	On	January	29,	2019,	FHN	announced	a	$250	million	
increase	in	that	authority	(to	$500	million	total)	along	with	
an	extension	of	the	expiration	date	to	January	31,	2021.	
The	2018	program	has	been	terminated,	as	described	in	
the	next	paragraph.	

On	January	27,	2021,	FHN	announced	that	its	Board	
approved	a	new	$500	million	common	share	purchase	
program	that	was	to	expire	on	January	31,	2023,	replacing	

Table	7.22a

FHN’s	website	generally,	is	part	of	this	report	or	
incorporated	herein.

FHN	anticipates	that	it	will	continue	performing	an	annual	
enterprise-wide	stress	test	as	part	of	its	capital	and	risk	
management	process.	Results	of	this	test	will	be	
presented	to	executive	management	and	the	Board.

The	disclosures	in	this	“Stress	Testing”	section	include	
forward-looking	statements.	Please	refer	to	“Forward-
Looking	Statements”	for	additional	information	
concerning	the	characteristics	and	limitations	of	
statements	of	that	type.

the	2018	program,	which	was	terminated.	On	October	26,	
2021,	FHN	announced	that	the	2021	program	had	been	
increased	by	$500	million	and	extended	to	October	31,	
2023.	Like	the	2018	program,	the	2021	program	is	not	tied	
to	any	compensation	plan.	Purchases	may	be	made	in	the	
open	market	or	through	privately	negotiated	transactions,	
including	under	Rule	10b5-1	plans	as	well	as	accelerated	
share	repurchase	and	other	structured	transactions.	The	
timing	and	exact	amount	of	common	share	repurchases	
will	be	subject	to	various	factors,	including	FHN's	capital	
position,	financial	performance,	capital	impacts	of	
strategic	initiatives,	market	conditions	and	regulatory	
considerations.	

As	of	December	31,	2021,	$401	million	in	purchases	had	
been	made	life-to-date	under	this	authority	at	an	average	
price	per	share	of	$16.60,	or	$16.58	excluding	
commissions.	

COMMON	STOCK	PURCHASES—GENERAL	PROGRAM

(Dollar	values	and	volume	in	thousands,	
except	per	share	data)
2021

October	1	to	October	31
November	1	to	November	30
December	1	to	December	31

Total

(a)	 Represents	total	costs	including	commissions	paid

Compensation	Plans	Purchase	Program

A	consolidated	compensation	plan	share	purchase	
program	was	announced	on	August	6,	2004.	This	program	
consolidated	into	a	single	share	purchase	program	all	of	
the	previously	authorized	compensation	plan	share	
programs,	as	well	as	the	renewal	of	the	authorization	to	
purchase	shares	for	use	in	connection	with	two	
compensation	plans	for	which	the	share	purchase	

Total	number
of	shares
purchased

Average	price
paid	per	share	
(a)

Total	number	of
shares	purchased
as	part	of	publicly
announced	programs

Maximum	approximate	
dollar	value	that	may	
yet	be	purchased	under	
the	programs	

1,120	 $	
4,475	 $	
2,925	 $	
8,520	 $	

17.00	
17.19	
16.40	
16.89	

1,120	 $	
4,475	 $	
2,925	 $	
8,520	

723,523	
646,603	
598,646	

authority	had	expired.	The	total	amount	authorized	under	
this	consolidated	compensation	plan	share	purchase	
program	is	29.6	million	shares	calculated	before	adjusting	
for	stock	dividends	distributed	through	January	1,	2011.	
The	authorization	has	been	reduced	for	that	portion	which	
relates	to	compensation	plans	for	which	no	options	
remain	outstanding.	The	shares	may	be	purchased	over	
the	option	exercise	period	of	the	various	compensation	
plans	on	or	before	December	31,	2023.	Purchases	may	be	

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made	in	the	open	market	or	through	privately	negotiated	
transactions	and	are	subject	to	various	factors,	including	
FHN's	capital	position,	financial	performance,	capital	
impacts	of	strategic	initiatives,	market	conditions,	and	
regulatory	considerations.	As	of	December	31,	2021,	the	

Table	7.22b

maximum	number	of	shares	that	may	be	purchased	under	
the	program	was	23	million	shares.	Management	currently	
does	not	anticipate	purchasing	a	material	number	of	
shares	under	this	authority	during	2022.

COMMON	STOCK	PURCHASES—COMPENSATION	PLANS	PROGRAM

Total	number
of	shares
purchased

Average	price
paid	per	share

Total	number	of
shares	purchased
as	part	of	publicly
announced	programs

Maximum	number
of	shares	that	may
yet	be	purchased
under	the	programs

* $	
2	
5	
8	 $	

16.73	
17.30	
16.26	
16.59	

* 	
2	
5	
8	

23,150	
23,148	
23,143	

(Volume	in	thousands,	except	per	share	
data)
2021

October	1	to	October	31
November	1	to	November	30
December	1	to	December	31

Total

*	Amount	is	less	than	500	shares

Risk Management

FHN	derives	revenue	from	providing	services	and,	in	many	
cases,	assuming	and	managing	risk	for	profit	which	
exposes	FHN	to	business	strategy	and	reputational,	
liquidity,	market,	capital	adequacy,	operational,	
compliance,	legal,	and	credit	risks	that	require	ongoing	
oversight	and	management.	FHN	has	an	enterprise-wide	
approach	to	risk	governance,	measurement,	management,	
and	reporting	including	an	economic	capital	allocation	
process	that	is	tied	to	risk	profiles	used	to	measure	risk-
adjusted	returns.	Through	an	enterprise-wide	risk	
governance	structure	and	a	statement	of	risk	appetite	
approved	by	the	Board,	management	continually	
evaluates	the	balance	of	risk/return	and	earnings	volatility	
with	shareholder	value.

FHN’s	enterprise-wide	risk	governance	structure	begins	
with	the	Board.	The	Board,	working	with	the	Executive	&	
Risk	Committee	of	the	Board,	establishes	FHN’s	risk	
appetite	by	approving	policies	and	limits	that	provide	
standards	for	the	nature	and	the	level	of	risk	FHN	is	willing	
to	assume.	The	Board	regularly	receives	reports	on	
management’s	performance	against	FHN’s	risk	appetite	
primarily	through	the	Board’s	Executive	&	Risk	and	Audit	
Committees.

To	further	support	the	risk	governance	provided	by	the	
Board,	FHN	has	established	accountabilities,	control	
processes,	procedures,	and	a	management	governance	
structure	designed	to	align	risk	management	with	risk-
taking	throughout	FHN.	The	control	procedures	are	
aligned	with	FHN’s	four	components	of	risk	governance:	
(1)	Specific	Risk	Committees;	(2)	the	Risk	Management	
Organization;	(3)	Business	Unit	Risk	Management;	and	
(4)	Independent	Assurance	Functions.

1. Specific	Risk	Committees:	The	Board	has	delegated	
authority	to	the	Chief	Executive	Officer	to	manage	
Business	Strategy	and	Reputation	Risk,	and	the	general	
business	affairs	of	FHN	under	the	Board’s	oversight.	
The	CEO	utilizes	the	executive	management	team	and	
the	Management	Risk	Committee	to	carry	out	these	
duties	and	to	analyze	existing	and	emerging	strategic	
and	reputation	risks	and	determines	the	appropriate	
course	of	action.	The	Management	Risk	Committee	is	
comprised	of	the	CEO	and	certain	officers	designated	
by	the	CEO.	The	Management	Risk	Committee	is	
supported	by	a	set	of	specific	risk	committees	focused	
on	unique	risk	types	(e.g.	liquidity,	credit,	operational,	
etc.).	These	risk	committees	provide	a	mechanism	that	
assembles	the	necessary	expertise	and	perspectives	of	
the	management	team	to	discuss	emerging	risk	issues,	
monitor	FHN’s	risk-taking	activities,	and	evaluate	
specific	transactions	and	exposures.	These	committees	
also	monitor	the	direction	and	trend	of	risks	relative	to	
business	strategies	and	market	conditions	and	direct	
management	to	respond	to	risk	issues.

2. The	Risk	Management	Organization:	FHN’s	risk	

management	organization,	led	by	the	Chief	Risk	Officer	
and	Chief	Credit	Officer,	provides	objective	oversight	
of	risk-taking	activities.	The	risk	management	
organization	translates	FHN’s	overall	risk	appetite	into	
approved	limits	and	formal	policies	and	is	supported	by	
corporate	staff	functions,	including	the	Corporate	
Secretary,	Legal,	Finance,	Human	Resources,	and	
Technology.	Risk	management	also	works	with	
business	units	and	functional	experts	to	establish	
appropriate	operating	standards	and	monitor	business	
practices	in	relation	to	those	standards.	Additionally,	
risk	management	proactively	works	with	business	units	

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and	senior	management	to	focus	management	on	key	
risks	in	FHN	and	emerging	trends	that	may	change	
FHN’s	risk	profile.	The	Chief	Risk	Officer	has	overall	
responsibility	and	accountability	for	enterprise	risk	
management	and	aggregate	risk	reporting.

4.

3. Business	Unit	Risk	Management:	FHN’s	business	units	

are	responsible	for	identifying,	acknowledging,	
quantifying,	mitigating,	and	managing	all	risks	arising	
within	their	respective	units.	They	determine	and	
execute	their	business	strategies,	which	puts	them	
closest	to	the	changing	nature	of	risks	and	they	are	
best	able	to	take	the	needed	actions	to	manage	and	
mitigate	those	risks.	The	business	units	are	supported	
by	the	risk	management	organization	that	helps	
identify	and	consider	risks	when	making	business	
decisions.	Management	processes,	structure,	and	
policies	are	designed	to	help	ensure	compliance	with	
laws	and	regulations	as	well	as	provide	organizational	
clarity	for	authority,	decision-making,	and	
accountability.	The	risk	governance	structure	supports	
and	promotes	the	escalation	of	material	items	to	
executive	management	and	the	Board.

Market Risk Management

Market	risk	is	the	risk	that	changes	in	market	conditions	
will	adversely	impact	the	value	of	assets	or	liabilities,	or	
otherwise	negatively	impact	FHN’s	earnings.	Market	risk	is	
inherent	in	the	financial	instruments	associated	with	
FHN’s	operations,	primarily	trading	activities	within	FHN	
Financial,	but	also	through	non-trading	activities	which	are	
primarily	affected	by	interest	rate	risk	that	is	managed	by	
the	ALCO	within	FHN.	

FHN	is	exposed	to	market	risk	related	to	the	trading	
securities	inventory	and	loans	held	for	sale	maintained	by	
FHN	Financial	in	connection	with	its	fixed	income	
distribution	activities.	Various	types	of	securities	inventory	
positions	are	procured	for	distribution	to	clients	by	the	
sales	staff.	When	these	securities	settle	on	a	delayed	
basis,	they	are	considered	forward	contracts.	Refer	to	the	
"Determination	of	Fair	Value	-	Trading	securities	and	
trading	liabilities"	section	of	Note	24	-	Fair	Value	of	Assets	
and	Liabilities,	which	section	is	incorporated	into	this	
MD&A	by	this	reference.	

FHN’s	market	risk	appetite	is	approved	by	the	Executive	&	
Risk	Committee	of	the	Board	of	Directors	and	executed	
through	management	policies	and	procedures	of	ALCO	
and	the	FHN	Financial	Risk	Committee.	These	policies	
contain	various	market	risk	limits	including,	for	example,	

Independent	Assurance	Functions:	Internal	Audit,	
Credit	Assurance	Services,	Compliance	Testing,	and	
Model	Validation	provide	an	independent	and	
objective	assessment	of	the	design	and	execution	of	
FHN’s	internal	control	system,	including	management	
processes,	risk	governance,	and	policies	and	
procedures.	These	groups’	activities	are	designed	to	
provide	reasonable	assurance	that	risks	are	
appropriately	identified	and	communicated;	resources	
are	safeguarded;	significant	financial,	managerial,	and	
operating	information	is	complete,	accurate,	and	
reliable;	and	employee	actions	are	in	compliance	with	
FHN’s	policies	and	applicable	laws	and	regulations.	
Internal	Audit	and	CAS	report	to	the	Chief	Audit	
Executive,	who	is	appointed	by	and	reports	to	the	
Audit	Committee	of	the	Board.	Internal	Audit	reports	
quarterly	to	the	Audit	Committee	of	the	Board,	while	
CAS	reports	quarterly	to	the	Executive	&	Risk	
Committee	of	the	Board.	Compliance	Testing	and	
Model	Validation	report	to	the	Chief	Risk	Officer	and	
report	annually	to	the	Audit	Committee	of	the	Board.

VaR	limits	for	the	trading	securities	inventory,	and	
individual	position	limits	and	sector	limits	for	products	
with	credit	risk,	among	others.	Risk	measures	are	
computed	and	reviewed	on	a	daily	basis	to	ensure	
compliance	with	market	risk	management	policies.

Value-at-Risk	and	Stress	Testing

VaR	is	a	statistical	risk	measure	used	to	estimate	the	
potential	loss	in	value	from	adverse	market	movements	
over	an	assumed	fixed	holding	period	within	a	stated	
confidence	level.	FHN	employs	a	model	to	compute	daily	
VaR	measures	for	its	trading	securities	inventory.	FHN	
computes	VaR	using	historical	simulation	with	a	1-year	
lookback	period	at	a	99%	confidence	level	with	1-day	and	
10-day	time	horizons.	Additionally,	FHN	computes	a	
Stressed	VaR	measure.	The	SVaR	computation	uses	the	
same	model	but	with	model	inputs	reflecting	historical	
data	from	a	continuous	12-month	period	that	reflects	a	
period	of	significant	financial	stress	appropriate	for	our	
trading	securities	portfolio.

A	summary	of	FHN's	VaR	and	SVaR	measures	for	1-day	
and	10-day	time	horizons	is	presented	in	the	following	
table:

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Table	7.23

ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

(Dollars	in	millions)
1-day

VaR

SVaR

10-day

VaR

SVaR

(Dollars	in	millions)
1-day

VaR

SVaR

10-day

VaR

SVaR

$	

$	

VaR	&	SVaR	MEASURES

Year	Ended	December	31,	2021

Mean

High

Low

As	of
December	31,	2021

1	 $	

4	

4	 $	

7	

1	 $	

2	

5	

18	

21	

27	

1	

11	

2	

5	

5	

22	

Year	Ended	December	31,	2020

Mean

High

Low

As	of
December	31,	2020

3	 $	

5	

13	

18	

7	 $	

1	 $	

18	

25	

43	

1	

2	

6	

2	

2	

10	

10	

FHN’s	overall	VaR	measure	includes	both	interest	rate	risk	and	credit	spread	risk.	Separate	measures	of	these	component	risks	
are	as	follows:

Table	7.24

(Dollars	in	millions)
Interest	rate	risk

Credit	spread	risk

SCHEDULE	OF	RISKS	INCLUDED	IN	VaR

As	of	December	31,	2021

As	of	December	31,	2020

1-day

10-day

1-day

10-day

$	

1	 $	

1	

1	 $	

1	

1	 $	

2	

2	

6	

The	potential	risk	of	loss	reflected	by	FHN’s	VaR	measures	
assumes	the	trading	securities	inventory	is	static.	Because	
FHN	Financial	procures	fixed	income	securities	for	
purposes	of	distribution	to	clients,	its	trading	securities	
inventory	turns	over	regularly.	Additionally,	FHNF	traders	
actively	manage	the	trading	securities	inventory	
continuously	throughout	each	trading	day.	Accordingly,	
FHNF’s	trading	securities	inventory	is	highly	dynamic,	
rather	than	static.	As	a	result,	it	would	be	rare	for	FHNF	to	
incur	a	negative	revenue	day	in	its	fixed	income	activities	
at	the	levels	indicated	by	its	VaR	measures.	

In	addition	to	being	used	in	FHN’s	daily	market	risk	
management	process,	the	VaR	and	SVaR	measures	are	
also	used	by	FHN	in	computing	its	regulatory	market	risk	
capital	requirements	in	accordance	with	the	Market	Risk	
Capital	rules.	For	additional	information	regarding	FHN's	
capital	adequacy	refer	to	the	Capital	section	of	this	
MD&A.

FHN	also	performs	stress	tests	on	its	trading	securities	
portfolio	to	calculate	the	potential	loss	under	various	

assumed	market	scenarios.	Key	assumed	stresses	used	in	
those	tests	are:

Down	25	bps	-	assumes	an	instantaneous	downward	
move	in	interest	rates	of	25	basis	points	at	all	points	on	
the	interest	rate	yield	curve.

Up	25	bps	-	assumes	an	instantaneous	upward	move	in	
interest	rates	of	25	basis	points	at	all	points	on	the	
interest	rate	yield	curve.

Curve	flattening	-	assumes	an	instantaneous	flattening	
of	the	interest	rate	yield	curve	through	an	increase	in	
short-term	rates	and	a	decrease	in	long-term	rates.	The	
2-year	point	on	the	Treasury	yield	curve	is	assumed	to	
increase	15	basis	points	and	the	10-year	point	on	the	
Treasury	yield	curve	is	assumed	to	decrease	15	basis	
points.	Shifts	in	other	points	on	the	yield	curve	are	
predicted	based	on	their	correlation	to	the	2-year	and	
10-year	points.

Curve	steepening	-	assumes	an	instantaneous	
steepening	of	the	interest	rate	yield	curve	through	a	
decrease	in	short-term	rates	and	an	increase	in	long-

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term	rates.	The	2-year	point	on	the	Treasury	yield	curve	
is	assumed	to	decrease	15	basis	points	and	the	10-year	
point	on	the	Treasury	yield	curve	is	assumed	to	increase	
15	basis	points.	Shifts	in	other	points	on	the	yield	curve	
are	predicted	based	on	their	correlation	to	the	2-year	
and	10-year	points.

Credit	spread	widening	-	assumes	an	instantaneous	
increase	in	credit	spreads	(the	difference	between	yields	
on	Treasury	securities	and	non-Treasury	securities)	of	25	
basis	points.

Model	Validation

Trading	risk	management	personnel	within	FHN	Financial	
have	primary	responsibility	for	model	risk	management	

Interest Rate Risk Management

Interest	rate	risk	is	the	risk	to	earnings	or	capital	arising	
from	movement	in	interest	rates.	ALCO	is	responsible	for	
overseeing	the	management	of	existing	and	emerging	
interest	rate	risk	for	the	company	within	risk	tolerances	
established	by	the	Board.	FHN	primarily	manages	interest	
rate	risk	by	structuring	the	balance	sheet	to	maintain	a	
desired	level	of	associated	earnings	and	to	protect	the	
economic	value	of	FHN’s	capital.

Net	interest	income	and	the	value	of	equity	are	affected	
by	changes	in	the	level	of	market	interest	rates	because	of	
the	differing	repricing	characteristics	of	assets	and	
liabilities,	the	exercise	of	prepayment	options	held	by	loan	
clients,	the	early	withdrawal	options	held	by	deposit	
clients,	and	changes	in	the	basis	between	and	changing	
shapes	of	the	various	yield	curves	used	to	price	assets	and	
liabilities.	To	isolate	the	repricing,	basis,	option,	and	yield	
curve	components	of	overall	interest	rate	risk,	FHN	
employs	Gap,	Earnings	at	Risk,	and	Economic	Value	of	
Equity	analyses	generated	by	a	balance	sheet	simulation	
model.	

Net	Interest	Income	Simulation	Analysis

The	information	provided	in	this	section,	including	the	
discussion	regarding	the	outcomes	of	simulation	analysis	
and	rate	shock	analysis,	is	forward-looking.	Actual	results,	
if	the	assumed	scenarios	were	to	occur,	could	differ	
because	of	interest	rate	movements,	the	ability	of	
management	to	execute	its	business	plans,	and	other	
factors,	including	those	presented	in	the	Forward-Looking	
Statements	section	of	this	Report.

Management	uses	a	simulation	model	to	measure	interest	
rate	risk	and	to	formulate	strategies	to	improve	balance	
sheet	positioning,	earnings,	or	both,	within	FHN’s	interest	
rate	risk,	liquidity,	and	capital	guidelines.	Interest	rate	
exposure	is	measured	by	forecasting	12	months	of	NII	
under	various	interest	rate	scenarios	and	comparing	the	
percentage	change	in	NII	for	each	scenario	to	a	base	case	
scenario	where	interest	rates	remain	unchanged.	
Assumptions	are	made	regarding	future	balance	sheet	
composition,	interest	rate	movements,	and	loan	and	

with	respect	to	the	model	used	by	FHN	to	compute	its	VaR	
measures	and	perform	stress	testing	on	the	trading	
inventory.	Among	other	procedures,	these	personnel	
monitor	model	results	and	perform	periodic	backtesting	
as	part	of	an	ongoing	process	of	validating	the	accuracy	of	
the	model.	These	model	risk	management	activities	are	
subject	to	annual	review	by	FHN’s	Model	Validation	
Group,	an	independent	assurance	group	charged	with	
oversight	responsibility	for	FHN’s	model	risk	management.

deposit	pricing.	In	addition,	assumptions	are	made	about	
the	magnitude	of	asset	prepayments	and	earlier	than	
anticipated	deposit	withdrawals.	The	results	of	these	
scenarios	help	FHN	develop	strategies	for	managing	
exposure	to	interest	rate	risk.	While	management	believes	
the	assumptions	used	and	scenarios	selected	in	its	
simulations	are	reasonable,	simulation	modeling	provides	
only	an	estimate,	not	a	precise	calculation,	of	exposure	to	
any	given	change	in	interest	rates.	

Based	on	a	static	balance	sheet	as	of	December	31,	2021,	
NII	exposures	over	the	next	12	months	assuming	rate	
shocks	of	plus	25	basis	points,	50	basis	points,	100	basis	
points,	and	200	basis	points	are	estimated	to	have	
favorable	variances	as	shown	in	the	table	below.

Table	7.25

INTEREST	RATE	SENSITIVITY

Shifts	in	Interest	Rates
(in	bps)

%	Change	in	Projected	Net	
Interest	Income

+25

+50

+100

+200

3.7%

7.6%

16.4%

29.5%

A	steepening	yield	curve	scenario	where	long-term	rates	
increase	by	50	basis	points	and	short-term	rates	are	static,	
results	in	a	favorable	NII	variance	of	0.8%.	A	flattening	
yield	curve	scenario	where	long-term	rates	decrease	by	50	
basis	points	and	short-term	rates	are	static,	results	in	an	
unfavorable	NII	variance	of	1.1%.	Rate	shocks	of	minus	25	
basis	points	and	50	basis	points	result	in	unfavorable	NII	
variances	of	1.9%	and	2.7%,	assuming	the	absence	of	
negative	rates.	These	hypothetical	scenarios	are	used	to	
create	a	risk	measurement	framework,	and	do	not	
necessarily	represent	management’s	current	view	of	
future	interest	rates	or	market	developments.

FHN’s	net	interest	income	has	been	impacted	by	the	
disruption	from	the	COVID-19	pandemic	and	its	variants	as	
well	as	the	low-rate	environment.	The	impact	of	

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government	stimulus	programs	and	other	developments	
have	also	influenced	net	interest	income	results,	although	
the	impacts	from	these	programs	have	abated,	and	
interest	rates	are	expected	to	increase	in	the	future.	FHN	
continues	to	monitor	current	economic	trends	and	
potential	exposures	closely.	

Fair	Value	Shock	Analysis

Interest	rate	risk	and	the	slope	of	the	yield	curve	also	
affect	the	fair	value	of	FHN's	trading	inventory	that	is	
reflected	in	noninterest	income.	

Generally,	low	or	declining	interest	rates	with	a	positively	
sloped	yield	curve	tend	to	increase	income	through	higher	
demand	for	fixed	income	products.	Additionally,	the	fair	
value	of	FHN's	trading	inventory	can	fluctuate	as	a	result	
of	differences	between	current	interest	rates	and	the	
interest	rates	of	fixed	income	securities	in	the	trading	
inventory.

Derivatives

In	the	normal	course	of	business,	FHN	utilizes	various	
financial	instruments	(including	derivative	contracts	and	

Capital Risk Management & Adequacy

The	capital	management	objectives	of	FHN	are	to	provide	
capital	sufficient	to	cover	the	risks	inherent	in	FHN’s	
businesses,	to	maintain	excess	capital	to	well-capitalized	
standards	and	Board	policy,	and	to	assure	ready	access	to	
the	capital	markets.	The	Capital	&	Stress	Testing	
Committee,	chaired	by	the	Corporate	Treasurer,	reports	
to	ALCO	and	is	responsible	for	capital	management	
oversight	and	provides	a	forum	for	addressing	
management	issues	related	to	capital	adequacy.	This	
committee	reviews	sources	and	uses	of	capital,	key	capital	

Operational Risk Management

Operational	risk	is	the	risk	of	loss	from	inadequate	or	
failed	internal	processes,	people,	or	systems	or	from	
external	events	including	data	or	network	security	
breaches	of	FHN	or	of	third	parties	affecting	FHN	or	its	
clients.	This	risk	is	inherent	in	all	businesses.	Operational	
risk	is	divided	into	the	following	risk	areas,	which	have	
been	established	at	the	corporate	level	to	address	these	
risks	across	the	entire	organization:

• Business	Resilience

• Records	Management

• Compliance/Legal	(including	Bank	Secrecy	Act)

• Program	Governance
• Fiduciary

• Security/Fraud

• Financial	(including	disclosure	controls	and	

procedures)

• Information	Technology	(including	cybersecurity)

• Model

credit-related	agreements)	to	manage	the	risk	of	loss	
arising	from	adverse	changes	in	the	fair	value	of	certain	
financial	instruments	generally	caused	by	changes	in	
interest	rates,	including	FHN's	securities	inventory,	certain	
term	borrowings,	and	certain	loans.	Additionally,	FHN	may	
enter	into	derivative	contracts	in	order	to	meet	clients'	
needs.	However,	such	derivative	contracts	are	typically	
offset	with	a	derivative	contract	entered	into	with	an	
upstream	counterparty	in	order	to	mitigate	risk	associated	
with	changes	in	interest	rates.

The	simulation	models	and	related	hedging	strategies	
discussed	above	exclude	the	dynamics	related	to	how	fee	
income	and	noninterest	expense	may	be	affected	by	
actual	changes	in	interest	rates	or	expectations	of	
changes.	See	Note	22	-	Derivatives	for	additional	
discussion	of	these	instruments.

ratios,	segment	economic	capital	allocation	
methodologies,	coordinates	the	annual	enterprise-wide	
stress	testing	process,	and	other	factors	in	monitoring	and	
managing	current	capital	levels,	as	well	as	potential	future	
sources	and	uses	of	capital.	The	Capital	&	Stress	Testing	
Committee	also	recommends	capital	management	
policies,	which	are	submitted	for	approval	to	ALCO	and	
the	Executive	&	Risk	Committee	and	the	Board	as	
necessary.

• Vendor

• Insurance

Management,	measurement,	and	reporting	of	operational	
risk	are	overseen	by	the	Operational	Risk,	Fiduciary,	
Financial	Governance,	FHN	Financial	Risk,	and	Strategic	
Investment	Board	Committees.	Key	representatives	from	
the	business	segments,	operating	units,	and	supporting	
units	are	represented	on	these	committees	as	
appropriate.	These	governance	committees	manage	the	
individual	operational	risk	types	across	FHN	by	setting	
standards,	monitoring	activity,	initiating	actions,	and	
reporting	exposures	and	results.	Key	Committee	activities	
and	decisions	are	reported	to	the	appropriate	governance	
committee	or	included	in	the	Enterprise	Risk	Report,	a	
quarterly	analysis	of	risk	within	the	organization	that	is	
provided	to	the	Executive	and	Risk	Committee.	Emphasis	
is	dedicated	to	refinement	of	processes	and	tools	to	aid	in	
measuring	and	managing	material	operational	risks	and	
providing	for	a	culture	of	awareness	and	accountability.

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Compliance Risk Management

Compliance	risk	is	the	risk	of	legal	or	regulatory	sanctions,	
material	financial	loss,	or	loss	to	reputation	as	a	result	of	
failure	to	comply	with	laws,	regulations,	rules,	self-
regulatory	organization	standards,	and	codes	of	conduct	
applicable	to	FHN’s	activities.	Management,	
measurement,	and	reporting	of	compliance	risk	are	
overseen	by	the	Operational	Risk	Committee	and	other	
key	Corporate	Governance	Committees.	Key	executives	

Credit Risk Management

Credit	risk	is	the	risk	of	loss	due	to	adverse	changes	in	a	
borrower’s	or	counterparty’s	ability	to	meet	its	financial	
obligations	under	agreed	upon	terms.	FHN	is	subject	to	
credit	risk	in	lending,	trading,	investing,	liquidity/funding,	
and	asset	management	activities	although	lending	
activities	have	the	most	exposure	to	credit	risk.	The	nature	
and	amount	of	credit	risk	depends	on	the	types	of	
transactions,	the	structure	of	those	transactions,	collateral	
received,	the	use	of	guarantors	and	the	parties	involved.	

FHN	assesses	and	manages	credit	risk	through	a	series	of	
policies,	processes,	measurement	systems,	and	controls.	
The	Credit	Risk	Management	Committee	is	responsible	for	
overseeing	the	management	of	existing	and	emerging	
credit	risks	in	the	company	within	the	broad	risk	
tolerances	established	by	the	Board.	The	CRMC	reports	
through	the	Management	Risk	Committee.	The	Credit	Risk	
Management	function,	led	by	the	Chief	Credit	Officer,	
provides	strategic	and	tactical	credit	leadership	by	
maintaining	policies,	overseeing	credit	approval,	assessing	
new	credit	products,	strategies	and	processes,	and	
managing	portfolio	composition	and	performance.	

While	the	Credit	Risk	function	oversees	FHN’s	credit	risk	
management,	there	is	significant	coordination	between	
the	business	lines	and	the	Credit	Risk	function	in	order	to	
manage	FHN’s	credit	risk	and	maintain	strong	asset	
quality.	The	Credit	Risk	function	recommends	portfolio,	
industry/sector,	and	individual	client	limits	to	the	
Executive	&	Risk	Committee	of	the	Board	for	approval.	
Adherence	to	these	approved	limits	is	vigorously	
monitored	by	Credit	Risk	which	provides	
recommendations	to	slow	or	cease	lending	to	the	business	
lines	as	commitments	near	established	lending	limits.	
Credit	Risk	also	ensures	subject	matter	experts	are	

Liquidity Risk Management

Among	other	things,	ALCO	is	responsible	for	liquidity	
management:	the	funding	of	assets	with	liabilities	of	
appropriate	duration,	while	mitigating	the	risk	of	
unexpected	cash	needs.	ALCO	and	the	Board	of	Directors	
have	adopted	a	Liquidity	Policy	of	which	the	objective	is	to	
ensure	that	FHN	meets	its	cash	and	collateral	obligations	
promptly,	in	a	cost-effective	manner	and	with	the	highest	
degree	of	reliability.	The	maintenance	of	adequate	levels	
of	asset	and	liability	liquidity	should	provide	FHN	with	the	

from	the	business	segments,	legal,	compliance,	risk	
management,	and	service	functions	are	represented	on	
the	Committees.	Summary	reports	of	Committee	activities	
and	decisions	are	provided	to	the	appropriate	governance	
committees.	Reports	include	the	status	of	regulatory	
activities,	internal	compliance	program	initiatives,	
compliance	testing	results	and	evaluation	of	emerging	
compliance	risk	areas.

providing	oversight,	support	and	credit	approvals,	
particularly	in	the	specialty	lending	areas	where	industry-
specific	knowledge	is	required.	Management	emphasizes	
general	portfolio	servicing	such	that	emerging	risks	are	
able	to	be	spotted	early	enough	to	correct	potential	
deficiencies,	prevent	further	credit	deterioration,	and	
mitigate	credit	losses.	

The	Credit	Risk	Management	function	assesses	the	asset	
quality	trends	and	results,	as	well	as	lending	processes,	
adherence	to	underwriting	guidelines	(portfolio-specific	
underwriting	guidelines	are	discussed	further	in	the	Asset	
Quality	Trends	section),	and	utilizes	this	information	to	
inform	management	regarding	the	current	state	of	credit	
quality	and	as	a	factor	of	the	estimation	process	for	
determining	the	allowance	for	credit	losses.	The	CRMC	
reviews	on	a	periodic	basis	various	reports	issued	by	
assurance	functions	which	provide	an	independent	
assessment	of	the	adequacy	of	loan	servicing,	grading	
accuracy,	and	other	key	functions.	Additionally,	CRMC	is	
presented	with	and	discusses	various	portfolios,	lending	
activity	and	lending-related	projects.	

All	of	the	above	activities	are	subject	to	independent	
review	by	FHN’s	Credit	Assurance	Services	Group.	CAS	
reports	to	the	Chief	Audit	Executive,	who	is	appointed	by	
and	reports	to	the	Audit	Committee	of	the	Board,	and	
provides	quarterly	reports	to	the	Executive	&	Risk	
Committee	of	the	Board.	CAS	is	charged	with	providing	
the	Executive	&	Risk	Committee	of	the	Board	and	
executive	management	with	independent,	objective,	and	
timely	assessments	of	FHN’s	portfolio	quality,	credit	
policies,	and	credit	risk	management	processes.

ability	to	meet	both	expected	and	unexpected	cash	and	
collateral	needs.	Key	liquidity	ratios,	asset	liquidity	levels,	
and	the	amount	available	from	funding	sources	are	
reported	to	ALCO	on	a	regular	basis.	FHN’s	Liquidity	Policy	
establishes	liquidity	limits	that	are	deemed	appropriate	
for	FHN’s	risk	profile.	

In	accordance	with	the	Liquidity	Policy,	ALCO	manages	
FHN’s	exposure	to	liquidity	risk	through	a	dynamic,	real	

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time	forecasting	methodology.	Base	liquidity	forecasts	are	
reviewed	by	ALCO	and	are	updated	as	financial	conditions	
dictate.	In	addition	to	the	baseline	liquidity	reports,	robust	
stress	testing	of	assumptions	and	funds	availability	are	
periodically	reviewed.	FHN	maintains	a	contingency	
funding	plan	that	may	be	executed	should	unexpected	
difficulties	arise	in	accessing	funding	that	affects	FHN,	the	
industry,	or	both.	Subject	to	market	conditions	and	
compliance	with	applicable	regulatory	requirements	from	
time	to	time,	funds	are	available	from	a	number	of	
sources,	including	the	available-for-sale	securities	
portfolio,	dealer	and	commercial	customer	repurchase	
agreements,	access	to	the	overnight	and	term	Federal	
Funds	markets,	incremental	borrowing	capacity	at	the	
FHLB	($14.5	billion	was	available	at	December	31,	2021),	
brokered	deposits,	loan	sales,	syndications,	and	access	to	
the	Federal	Reserve	Bank.	

Core	deposits	are	a	significant	source	of	funding	and	have	
historically	been	a	stable	source	of	liquidity	for	banks.	
Generally,	core	deposits	represent	funding	from	a	
financial	institution's	client	base	which	provides	
inexpensive,	predictable	pricing.	The	FDIC	insures	these	
deposits	to	the	extent	authorized	by	law.	Generally,	these	
limits	are	$250,000	per	account	owner	for	interest-bearing	
and	noninterest-bearing	accounts.	The	ratio	of	average	
loans,	excluding	loans	HFS	and	restricted	real	estate	loans,	
to	average	core	deposits	was	80%	on	December	31,	2021	
compared	to	99%	on	December	31,	2020.

FHN	may	also	use	unsecured	short-term	borrowings	as	a	
source	of	liquidity.	Federal	funds	purchased	from	
correspondent	bank	clients	are	considered	to	be	
substantially	more	stable	than	funds	purchased	in	the	
national	broker	markets	for	federal	funds	due	to	the	long,	
historical,	and	reciprocal	nature	of	banking	services	
provided	by	FHN	to	these	correspondent	banks.	The	
remainder	of	FHN’s	wholesale	short-term	borrowings	
consists	of	securities	sold	under	agreements	to	repurchase	
transactions	accounted	for	as	secured	borrowings	with	
business	clients	or	broker	dealer	counterparties.

Both	FHN	and	First	Horizon	Bank	have	the	ability	to	
generate	liquidity	by	issuing	senior	or	subordinated	
unsecured	debt,	preferred	equity,	and	common	equity,	
subject	to	market	conditions	and	compliance	with	
applicable	regulatory	requirements.	In	May	2021,	FHN	
issued	$150	million	of	Series	F	Non-Cumulative	Perpetual	
Preferred	Stock	and	in	July	2021	redeemed	its	$100	
million	Series	A	Non-Cumulative	Perpetual	Preferred	
Stock.	As	of	December	31,	2021,	FHN	had	outstanding	
$1.3	billion	in	senior	and	subordinated	unsecured	debt	
and	$520	million	in	non-cumulative	perpetual	preferred	
stock.	As	of	December	31,	2021,	First	Horizon	Bank	and	
subsidiaries	had	outstanding	preferred	shares	of	$295	
million,	which	are	reflected	as	noncontrolling	interest	on	
the	Consolidated	Balance	Sheet.

Parent	company	liquidity	is	primarily	provided	by	cash	
flows	stemming	from	dividends	and	interest	payments	
collected	from	subsidiaries.	These	sources	of	cash	
represent	the	primary	sources	of	funds	to	pay	cash	
dividends	to	shareholders	and	principal	and	interest	to	
debt	holders	of	FHN.	The	amount	paid	to	the	parent	
company	through	First	Horizon	Bank	common	dividends	is	
managed	as	part	of	FHN’s	overall	cash	management	
process,	subject	to	applicable	regulatory	restrictions.	
Certain	regulatory	restrictions	exist	regarding	the	ability	of	
First	Horizon	Bank	to	transfer	funds	to	FHN	in	the	form	of	
cash,	common	dividends,	loans,	or	advances.	At	any	given	
time,	the	pertinent	portions	of	those	regulatory	
restrictions	allow	First	Horizon	Bank	to	declare	preferred	
or	common	dividends	without	prior	regulatory	approval	in	
an	aggregate	amount	equal	to	First	Horizon	Bank’s	
retained	net	income	for	the	two	most	recently	completed	
years	plus	the	current	year-to-date	period.	For	any	period,	
First	Horizon	Bank’s	"retained	net	income"	generally	is	
equal	to	First	Horizon	Bank’s	regulatory	net	income	
reduced	by	the	preferred	and	common	dividends	declared	
by	First	Horizon	Bank.	Applying	the	dividend	restrictions	
imposed	under	applicable	federal	and	state	rules	as	
outlined	above,	the	Bank’s	total	amount	available	for	
dividends	was	$1.1	billion	as	of	January	1,	2022.	
Consequently,	on	that	date	the	Bank	could	pay	common	
dividends	up	to	that	amount	to	its	sole	common	
shareholder,	FHN,	or	to	its	preferred	shareholders	without	
prior	regulatory	approval.	Additionally,	a	capital	
conservation	buffer	must	be	maintained	(as	described	in	
the	Capital	section	of	this	Report)	to	avoid	restrictions	on	
dividends.

First	Horizon	Bank	declared	and	paid	common	dividends	
to	the	parent	company	in	the	amount	of	$770	million	in	
2021	and	$180	million	in	2020.	In	January	2022,	First	
Horizon	Bank	declared	and	paid	a	common	dividend	to	the	
parent	company	in	the	amount	of	$180	million.	First	
Horizon	Bank	paid	preferred	dividends	in	each	quarter	of	
2021	and	2020	and	declared	preferred	dividends	in	the	
first	quarter	of	2022	which	are	payable	in	April	2022.

Payment	of	a	dividend	to	shareholders	of	FHN	is	
dependent	on	several	factors	which	are	considered	by	the	
Board.	These	factors	include	FHN’s	current	and	
prospective	capital,	liquidity,	and	other	needs,	as	well	as	
applicable	regulatory	restrictions	(including	capital	
conservation	buffer	requirements)	and	availability	of	
funds	to	FHN	through	a	dividend	from	First	Horizon	Bank.		
Additionally,	banking	regulators	generally	require	insured	
banks	and	bank	holding	companies	to	pay	cash	dividends	
only	out	of	current	operating	earnings.	Consequently,	the	
decision	of	whether	FHN	will	pay	future	dividends	and	the	
amount	of	dividends	will	be	affected	by	current	operating	
results.

FHN	paid	a	cash	dividend	of	$0.15	per	common	share	on	
January	3,	2022.	FHN	paid	cash	dividends	of	$1,625	per	
Series	E	preferred	share	and	$1,175	per	Series	F	preferred	

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share	on	January	10,	2022	and	$331.25	per	Series	B	
preferred	share	and	$165	per	Series	C	preferred	share	on	
February	1,	2022.	In	addition,	in	January	2022,	the	Board	
approved	cash	dividends	per	share	in	the	following	
amounts:

Table	7.26

CASH	DIVIDENDS	APPROVED	BUT	NOT	PAID

Dividend/
Share

Record	Date

Payment	Date

in	the	consolidated	financial	statements.	Such	activities	
include	traditional	off-balance	sheet	credit-related	
financial	instruments.	FHN	enters	into	commitments	to	
extend	credit	to	borrowers,	including	loan	commitments,		
lines	of	credit,	standby	letters	of	credit,	and	commercial	
letters	of	credit.	Many	of	the	commitments	are	expected	
to	expire	unused	or	be	only	partially	used;	therefore,	the	
total	amount	of	commitments	does	not	necessarily	
represent	future	cash	requirements	and	are	not	included	
in	the	table	below.	See	Note	17	-	Contingencies	and	Other	
Disclosures	for	more	information.

0.15	

3/11/2022

4/1/2022

Contractual	Obligations

Common	Stock

Preferred	Stock

Series	C

Series	D

Series	E

Series	F

$	

$	

$	

$	

$	

165.00	

4/14/2022

305.00	

4/14/2022

5/2/2022

5/2/2022

1,625.00	

3/25/2022

4/11/2022

1,175.00	

3/25/2022

4/11/2022

Off-Balance	Sheet	Arrangements

In	the	normal	course	of	business,	FHN	is	a	party	to	a	
number	of	activities	that	contain	credit,	market	and	
operational	risk	that	are	not	reflected	in	whole	or	in	part	

Table	7.27 

The	following	table	sets	forth	contractual	obligations	
representing	required	and	potential	cash	outflows	as	of	
December	31,	2021.	Purchase	obligations	represent	
obligations	under	agreements	to	purchase	goods	or	
services	that	are	enforceable	and	legally	binding	on	FHN	
and	that	specify	all	significant	terms,	including	fixed	or	
minimum	quantities	to	be	purchased;	fixed,	minimum,	or	
variable	price	provisions;	and	the	approximate	timing	of	
the	transaction.	

CONTRACTUAL	OBLIGATIONS
as	of	December	31,	2021	

(Dollars	in	millions)

Contractual	obligations:

Time	deposit	maturities	(b)	(c)

Term	borrowings	(b)	(d)

Annual	rental	commitments	under	noncancelable	leases	
(b)	(e)

Purchase	obligations

Total	contractual	obligations

Payments	due	by	period	(a)

Less	than

			1	year	-

					3	years	-

After	5

1	year

<	3	years

<	5	years

years

Total

$	

3,006	 $	

344	 $	

122	 $	

28	 $	

—	

49	

160	

456	

85	

145	

350	

76	

56	

807	

238	

13	

3,500	

1,613	

448	

374	

$	

3,215	 $	

1,030	 $	

604	 $	

1,086	 $	

5,935	

(a) Excludes	a	$92	million	liability	for	unrecognized	tax	benefits	as	the	timing	of	payment	cannot	be	reasonably	estimated.
(b) Amounts	do	not	include	interest.
(c) See	Note	9	-	Deposits	for	further	details.
(d) See	Note	11	-	Term	Borrowings	for	further	details.
(e) See	Note	6	-	Premises,	Equipment	and	Leases	for	further	details.

Credit Ratings

FHN	is	currently	able	to	fund	a	majority	of	the	balance	
sheet	through	core	deposits,	which	are	generally	not	as	
sensitive	to	FHN’s	credit	ratings	as	other	types	of	funding.	
However,	maintaining	adequate	credit	ratings	on	debt	
issues	and	preferred	stock	is	critical	to	liquidity	should	
FHN	need	to	access	funding	from	other	sources,	including	
from	long-term	debt	issuances	and	certain	brokered	
deposits,	at	an	attractive	rate.	The	availability	and	cost	of	
funds	other	than	core	deposits	is	also	dependent	upon	

marketplace	perceptions	of	the	financial	soundness	of	
FHN,	which	include	such	factors	as	capital	levels,	asset	
quality,	and	reputation.	The	availability	of	core	deposit	
funding	is	stabilized	by	federal	deposit	insurance,	which	
can	be	removed	only	in	extraordinary	circumstances,	but	
may	also	be	influenced	to	some	extent	by	the	same	
factors	that	affect	other	funding	sources.	FHN’s	credit	
ratings	are	also	referenced	in	various	respects	in	

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agreements	with	certain	derivative	counterparties	as	
discussed	in	Note	22	-	Derivatives.

The	following	table	provides	FHN’s	most	recent	credit	
ratings:

Table	7.28

First	Horizon	Corporation	

CREDIT	RATINGS	

Moody's		(a)

Fitch		(b)	

Overall	credit	rating:	Long-term/Short-term/Outlook

Baa3/--/Stable

BBB/F2/Positive

Long-term	senior	debt

Subordinated	debt	(c)
Junior	subordinated	debt	(c)

Preferred	stock

First	Horizon	Bank

Baa3

Baa3

Ba1
Ba2

BBB

BBB-

BB-
BB-

Overall	credit	rating:	Long-term/Short-term/Outlook

Baa3/P-2/Stable

BBB/F2/Positive

Long-term/short-term	deposits
Long-term/short-term	senior	debt	(c)

Subordinated	debt	

Preferred	stock

FT	Real	Estate	Securities	Company,	Inc.

Preferred	stock

A3/P-2
Baa3/P-2

Baa3

Ba2

Ba1

BBB+/F2
BBB/F2

BBB-

BB-

A	rating	is	not	a	recommendation	to	buy,	sell,	or	hold	securities	and	is	subject	to	revision	or	withdrawal	at	any	time	and	should	be	
evaluated	independently	of	any	other	rating.	
(a)	 Last	change	in	ratings	was	on	May	14,	2015;	ratings/outlook	affirmed	on	November	5,	2019.	
(b)	 Last	change	in	ratings	was	on	May	6,	2020;	ratings	affirmed	and	outlook	revised	to	Positive	on	May	18,	2021.	
(c)	 Ratings	are	preliminary/implied.	

Repurchase Obligations

Prior	to	September	2008,	legacy	First	Horizon	originated	
loans	through	its	pre-2009	mortgage	business,	primarily	
first	lien	home	loans,	with	the	intention	of	selling	them.	As	
discussed	in	Note	17	-	Contingencies	and	Other	
Disclosures,	FHN's	principal	remaining	exposures	for	those	
activities	relate	to	(i)	indemnification	claims	by	
underwriters,	loan	purchasers,	and	other	parties	which	
assert	that	FHN-originated	loans	caused	or	contributed	to	
losses	which	FHN	is	legally	obliged	to	indemnify,	and	(ii)	
indemnification	or	other	claims	related	to	FHN's	servicing	
of	pre-2009	mortgage	loans.	

Repurchase Accrual Approach

In	determining	potential	loss	content,	claims	are	analyzed	
by	purchaser,	vintage,	and	claim	type.	FHN	considers	
various	inputs	including	claim	rate	estimates,	historical	
average	repurchase	and	loss	severity	rates,	mortgage	
insurance	cancellations,	and	mortgage	insurance	
curtailment	requests.	Inputs	are	applied	to	claims	in	the	

FHN’s	approach	for	determining	the	adequacy	of	the	
repurchase	and	foreclosure	reserve	has	evolved,	
sometimes	substantially,	based	on	changes	in	information	
available.	Repurchase/make-whole	rates	vary	based	on	
purchaser,	vintage,	and	claim	type.	For	those	loans	
repurchased	or	covered	by	a	make-whole	payment,	
cumulative	average	loss	severities	range	between	50	and	
60	percent	of	the	UPB.

active	pipeline,	as	well	as	to	historical	average	inflows	to	
estimate	loss	content	related	to	potential	future	inflows.	
Management	also	evaluates	the	nature	of	claims	from	
purchasers	and/or	servicers	of	loans	sold	to	determine	if	
qualitative	adjustments	are	appropriate.

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Repurchase and Foreclosure Liability

FHN's	repurchase	and	foreclosure	liability,	primarily	
related	to	its	pre-2009	mortgage	business,	is	comprised	of	
accruals	to	cover	estimated	loss	content	in	the	active	
pipeline	(consisting	of	mortgage	loan	repurchase,	make-
whole,	foreclosure/servicing	demands	and	certain	related	
exposures),	estimated	future	inflows,	and	estimated	loss	
content	related	to	certain	known	claims	not	currently	
included	in	the	active	pipeline.	The	liability	contemplates	
repurchase/make-whole	and	damages	obligations	and	
estimates	for	probable	incurred	losses	associated	with	
loan	populations	excluded	from	the	settlements	with	the	

GSEs,	as	well	as	other	whole	loans	sold,	mortgage	
insurance	cancellations	rescissions,	and	loans	included	in	
bulk	servicing	sales	effected	prior	to	the	settlements	with	
the	GSEs.	FHN	compares	the	estimated	probable	incurred	
losses	determined	under	the	applicable	loss	estimation	
approaches	for	the	respective	periods	with	current	
reserve	levels.	Changes	in	the	estimated	required	liability	
levels	are	recorded	as	necessary	through	the	repurchase	
and	foreclosure	provision.	The	repurchase	and	foreclosure	
liability	was	$17	million	and	$16	million	as	of	
December	31,	2021	and	2020,	respectively.

Market Uncertainties & Prospective Trends

FHN’s	future	results	could	be	affected	both	positively	and	
negatively	by	several	known	trends.	Key	among	those	are	
changes	in	the	U.S.	and	global	economy	and	outlook,	
government	actions	affecting	interest	rates,	government	
actions	intended	to	stimulate	the	economy,	and	
government	actions	and	proposals	which	could	have	
negative	impacts	on	the	economy	at	large	or	on	certain	
businesses.	Additional	risks	relate	to	how	the	COVID-19	

Federal Reserve Policy in Transition

In	March	2020,	the	Federal	Reserve	"eased"	by	lowering	
short-term	interest	rates	and	starting	an	asset	purchase	
program	intended	to	lower	longer-term	interest	rates	and	
foster	access	to	credit.	The	effective	yields	of	10-year	and	
30-year	U.S.	Treasury	securities	achieved	record	low	rates.	
These	changes	in	interest	rates	and	the	volatility	in	the	
market	negatively	impacted	FHN’s	net	interest	margin.	
Amortization	of	net	processing	fees	related	to	government	
relief	programs	associated	with	the	COVID-19	pandemic,	
including	the	Paycheck	Protection	Program,	offset	a	
portion	of	the	net	interest	margin	decline.	

During	2021,	easing	policy	continued.	For	most	of	the	year	
interest	rates	fluctuated	but	remained	very	low,	
continuing	to	adversely	impact	FHN's	net	interest	margin.	
Late	in	2021	the	Federal	Reserve	announced	that	it	will	
moderate	and	eventually	reverse	its	easing	policy,	starting	
by	reducing	("tapering")	its	asset	purchases.	The	Federal	
Reserve's	public	comments	suggest	(without	any	
guarantee)	that	tapering	will	conclude	early	in	2022,	after	

COVID-19 Pandemic

The	COVID-19	pandemic	caused	extraordinary	disruption	
that	negatively	impacted	the	economy	and	business	
activity,	especially	lending	(other	than	lending	related	to	
home	mortgages).	The	impact	of	the	pandemic	on	FHN's	
performance	is	discussed	further	in	Results	of	Operations	
within	this	Item	7	beginning	on	page	63.	During	the	course	
of	2021,	FHN	saw	the	lending	pipeline	improve	in	several	
areas	(unrelated	to	home	mortgages)	as	COVID-19	
restrictions	were	partially	or	fully	eased	in	most	of	FHN's	

pandemic	continues	to	affect	FHN’s	clients,	political	
uncertainty,	changes	in	federal	policies	(including	those	
publicly	discussed,	formally	proposed,	or	recently	
implemented)	and	the	potential	impacts	of	those	changes	
on	our	businesses	and	clients,	and	whether	FHN’s	
strategic	initiatives	will	succeed.

which	no	further	asset	purchases	will	be	made,	and	that	
hikes	in	short-term	rates	will	commence	in	2022,	possibly	
in	the	first	quarter.	FHN	cannot	predict	whether	short	
term	interest	rates	will	be	raised	during	the	taper	period	
or	at	any	other	point	in	time.	

Long	term	interest	rates	started	to	rise	late	in	2021,	
continuing	in	2022,	though	they	remain	very	low	by	
historical	standards.	Public	expectations	related	to	
tapering,	coupled	with	public	Federal	Reserve	comments	
and	concerns	about	inflation	in	the	U.S.,	likely	have	been	
significant	contributors	to	recent	changes	in	long-term	
rates.	

Recently	the	Federal	Reserve	has	indicated	an	expectation	
to	reduce	its	asset	holdings	in	2022	after	purchases	have	
stopped.	Although	not	currently	expected,	it	is	possible	
that	the	Federal	Reserve	may	decide	to	sell	assets,	rather	
than	merely	letting	them	mature,	in	an	effort	to	increase	
long	term	interest	rates	more	quickly	or	more	robustly.	

markets.	Late	in	2021	and	continuing	into	early	2022,	the	
Omicron	variant	of	the	COVID-19	virus	has	triggered	
reinstatement	of	some	restrictions	in	some	markets.	Even	
so,	broadly	speaking	FHN	expects	the	impact	of	COVID-19	
restrictions	to	continue	to	diminish	over	the	rest	of	this	
year	with	further	progress	in	vaccination	rates	and	in	
treatments	for	those	who	are	infected.	However,	as	
demonstrated	by	variants	that	arose	in	2021,	the	risk	of	
resurgence	remains.	

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FHN	continues	to	closely	monitor	the	impact	of	the	
pandemic	and	its	effects	on	FHN's	clients	and	
communities	and	on	the	financial	markets.	Throughout	
the	pandemic,	FHN	has	worked	with	clients	to	discuss	
challenges	and	solutions,	provide	line	draws	and	new	

LIBOR & Reference Rate Reform

LIBOR

The	London	Inter-Bank	Offered	Rate	("LIBOR")	has	been	
the	most	widely	used	reference	rate	in	the	world	for	many	
years.	A	substantial	majority	of	FHN's	floating	rate	loans	
use	LIBOR,	denominated	in	U.S.	Dollars	("USD"),	as	the	
reference	rate	to	determine	the	interest	rate	paid	by	the	
client/borrower.	In	addition,	certain	floating-rate	
securities	issued	by	FHN	use	USD	LIBOR	as	the	reference	
rate.	

LIBOR	is	based	on	a	mix	of	transaction-based	data	and	
expert	judgment	about	market	conditions.	It	is	published	
in	different	tenors,	which	are	time	periods	such	as	1-week,	
1-month,	12-month,	etc.	

LIBOR	Discontinuance

About	a	decade	ago,	evidence	emerged	that	some	
members	of	the	panel	that	set	LIBOR	may	have	
manipulated	the	published	LIBOR	rates	rather	than	using	
strictly	good-faith	judgments.	Several	banks	were	fined.	

In	2017,	the	Chief	Executive	of	the	United	Kingdom	
Financial	Conduct	Authority	(the	“FCA”)—the	
governmental	regulator	of	LIBOR—announced	that	it	
intends	to	halt	persuading	or	compelling	banks	to	submit	
rates	for	the	calculation	of	LIBOR	after	2021.	In	2021,	the	
FCA	announced	that	tenors	of	USD	LIBOR	will	no	longer	be	
published	as	follows:

• One	week	and	2-month	USD	LIBOR	will	not	be	

published	after	December	31,	2021;	and

• All	other	USD	LIBOR	tenors	(e.g.,	overnight,	1-month,	
3-month,	6-month	and	12-month	tenors)	will	not	be	
published	after	June	30,	2023.

U.S.	Regulatory	Position

In	2020,	the	Federal	Reserve,	the	OCC,	and	the	FDIC	jointly	
encouraged	U.S.	banks	to	transition	away	from	LIBOR	for	
new	contracts	as	soon	as	practicable	and,	in	any	event,	by	
December	31,	2021.	They	noted	that	entering	into	new	
contracts	that	use	LIBOR	as	a	reference	rate	after	
December	31,	2021	would	create	safety	and	soundness	
risks.	

Alternatives	to	LIBOR

LIBOR	became	the	market-preferred	reference	rate	
because	it	was	perceived	by	lenders	and	borrowers	as	
being	superior	to	alternatives	in	a	wide	range	of	
circumstances.	FHN	believes	that	no	single	alternative	
reference	rate	will	immediately	replace	LIBOR	for	USD	
transactions.	Instead,	FHN	believes	it	is	likely	that	different	

extensions	to	existing	clients,	provide	support	for	small	
businesses	(including	lending	through	the	PPP),	and	
provide	lending	and	deposit	assistance	through	deferrals	
and	waived	fees.

alternatives	will	be	used	in	different	circumstances.	
Although	it	is	difficult	to	predict	which	alternatives	will	be	
favored	by	market	participants	in	any	particular	situation,	
at	this	time	it	seems	likely	that	the	following	alternative	
reference	rates	may	be	used	by	market	participants	once	
USD	LIBOR	is	discontinued:	

• SOFR.	The	Alternative	Reference	Rates	Committee	
(“ARRC”)	is	a	group	of	private-market	and	financial	
regulator	participants	convened	by	the	Federal	
Reserve	and	the	New	York	Federal	Reserve	Bank	to	
help	ensure	a	successful	transition	from	USD	LIBOR	to	
a	more	robust	reference	rate.	The	ARRC	has	
recommended	the	Secured	Overnight	Financing	Rate	
(“SOFR”)	as	its	preferred	alternative.	SOFR	is	based	on	
actual	transaction	data	for	the	U.S.	Treasury	
repurchase	market.	Accordingly,	SOFR	represents	a	
riskless	secured	overnight	rate.

• Term	SOFR.	Published	by	CME	Group,	Term	SOFR	is	a	
forward-looking	rate,	with	1-month,	3-month	and	6-
month	tenors,	and	is	based	on	SOFR	futures	
contracts.	The	ARRC	has	recommended	conventions	
for	Term	SOFR	rates	and	has	recommended	CME	
Group	as	the	administrator	for	Term	SOFR.

• AMERIBOR.	The	American	Interbank	Offered	Rate	
(“AMERIBOR”)	Index	is	produced	by	the	American	
Financial	Exchange.	AMERIBOR	is	based	on	actual	
transaction	data	involving	credit	decisions	by	many	
financial	institutions,	on	an	unsecured	basis.

• BSBY.	The	Bloomberg	short-term	bank	yield	index	
("BSBY")	is	a	proprietary	rate	index	calculated	and	
published	by	Bloomberg	Index	Services	Limited.	BSBY	
is	based	on	actual	transaction	data	involving	
unsecured	credit.

• Prime.	Although	traditional	prime	rates	(with	each	
bank	setting	its	own)	are	not	likely	to	regain	the	
prominence	they	had	decades	ago	when	U.S.	banks	
were	much	smaller	and	the	industry	was	more	
fragmented,	for	some	clients	and	products	banks	may	
increase	their	usage	of	prime	rates.

The	alternatives	listed	above	were	made	available	to	the	
majority	of	FHN’s	commercial	clients	starting	in	November	
2021.	In	accordance	with	the	U.S.	regulatory	position,	FHN	
ceased	entering	into	new	LIBOR	based	contracts	as	of	
December	31,	2021.	Other	alternative	reference	rates	are	
being	developed	and	FHN	may	consider	them	at	a	future	
time.

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Each	alternative	reference	rate	has	advantages	and	
disadvantages	compared	with	other	alternatives	in	various	
circumstances.	Despite	being	supported	by	the	Federal	
Reserve's	ARRC,	SOFR	may	not	gain	the	level	of	market	
acceptance	and	usage	that	USD	LIBOR	enjoyed	within	the	
U.S.	Key	aspects	of	SOFR	that	support	this	view	are:	(a)	
SOFR	fundamentally	is	an	overnight	rate,	and	so	is	not	
easily	or	reliably	translated	into	typical	LIBOR	tenors;	and	
(b)	SOFR	is	both	secured	and	riskless,	and	so	does	not	
necessarily	track	a	bank's	cost	of	funds	very	well.	For	a	
bank,	it	is	critical	to	avoid	significant	mismatches	over	
time	between	its	(variable)	cost	of	funds	and	its	(variable)	
interest	income.	Term	SOFR	attempts	to	address	some	of	
these	shortcomings,	but	not	all	of	them.

All	of	the	alternative	reference	rates	selected	by	FHN	to	
date	meet	the	International	Organization	of	Securities	
Commissions	(IOSCO)	Principles	for	Financial	Benchmarks,	
as	affirmed	by	the	rate	administrator	and/or	an	
independent	auditor.	While	banking	regulators	have	
stated	that	banks	are	free	to	choose	the	index	rates	they	
offer	clients,	some	public	sector	officials	have	urged	
caution	in	using	the	new	credit	sensitive	alternative	
reference	rates,	primarily	due	to	the	robustness	of	
underlying	data	used	to	derive	the	rates.	More	specifically,	
there	is	concern	of	an	“inverted	pyramid”	effect	where	a	
large	number	of	financial	contracts	could	be	priced	using	
an	index	derived	from	a	relatively	low	volume	of	
transactions.	In	an	interagency	statement	on	October	20,	
2021,	U.S.	banking	regulatory	agencies	noted	that	
“supervised	institutions	should	understand	how	their	
chosen	reference	rate	is	constructed	and	be	aware	of	any	
fragilities	associated	with	that	rate	and	the	markets	that	
underlie	it”.	IOSCO	has	also	warned	of	the	potential	for	
the	“inverted	pyramid”	problem	and	will	monitor	how	the	
IOSCO	label	is	used	by	administrators.

FHN	is	monitoring	the	credit	sensitive	reference	rates	and	
regulatory	guidance	around	use	of	such	rates.	FHN	plans	
to	limit	use	of	credit	sensitive	rates	to	commercial	loans	
(~2%	of	global	USD	LIBOR	market)	and	related	customer	
swaps	(pending	development	of	derivatives	markets	for	
these	rates).	Additionally,	FHN	expects	that	each	financial	
contract	will	contain	fallback	language	to	guide	transition	
from	a	credit	sensitive	rate	to	an	alternative	should	that	
action	be	deemed	necessary	in	the	future.	

FHN's	Actions	to	Date	&	Transition	Plans

Starting	in	2019,	legacy	First	Horizon	and	legacy	
IBERIABANK	both	modernized	the	fallback	language	used	
in	their	loan	documentation	to	better	handle	how	floating	
rate	loans	would	be	re-set	if	LIBOR	ceased	to	be	published	
during	the	loan	term.	

In	the	fourth	quarter	of	2021,	FHN	ceased	using	USD	
LIBOR	for	new	lending	and	renegotiated	terms	with	clients	
whose	loans	are	based	on	1-week	or	2-month	USD	LIBOR,	
which	ceased	publication	at	the	end	of	2021.	Only	a	small	
portion	of	FHN's	clients	had	such	loans.

On	the	consumer	side,	the	only	LIBOR-based	product	FHN	
currently	offers	was	adjustable	rate	mortgages.	For	new	
originations,	these	products	transitioned	to	SOFR	
beginning	in	November	2021.	SOFR	is	emerging	as	a	
market	standard	for	adjustable	rate	mortgages	and	is	the	
conforming	convention	for	Fannie	Mae	and	Freddie	Mac.

For	all	products,	FHN	developed	a	go-to-market	strategy	
which	included	pricing	considerations,	associate	training,	
and	client	communications.	All	required	systems,	
processes,	and	reporting	were	updated	to	accommodate	
the	transition.	Each	of	the	leading	alternatives	mentioned	
above	is	undergoing	further	development	and	refinement,	
and	it	remains	unclear	which	alternative(s)	FHN	and	its	
clients	generally	will	prefer,	and	in	which	situations.	Given	
these	considerations,	FHN's	plans	may	change	to	meet	
evolving	market	conditions	and	preferences.

FHN	has	established	a	LIBOR	Transition	Office	to	assist	
associates	in	working	with	their	clients	to	re-negotiate	
terms	of	loan	and	derivative	contracts	that	extend	past	
the	June	30,	2023	cessation	date	for	the	remaining	USD	
LIBOR	tenors	noted	above.		

While	FHN	has	exposure	to	LIBOR	in	various	contracts	(e.g.	
securities,	derivatives),	FHN's	primary	exposure	to	LIBOR	is	
in	floating	rate	loans	to	customers	and	derivative	
contracts	issued	to	customers	through	FHN	Financial.	
Below	is	a	summary	of	these	exposures	as	of	December	
31,	2021:

Table	7.29

LIBOR	EXPOSURES	

(Dollars	in	billions)

Commercial	loans	(a)

$	

Consumer	loans	(a)

Customer	swaps	(b)

As	of	
December	31,	
2021

Mature	after	
June	2023

25	 $	

4	

11	

17	

4	

10	

(a)	Amounts	represent	outstanding	loan	balances	as	of	December	31,	
2021.
(b)	FHN	has	entered	into	offsetting	upstream	transactions	with	dealers	to	
offset	its	market	risk	exposure.

FHN	is	assessing	the	potential	impacts	on	LIBOR-based	
securities	and	derivative	instruments.

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ITEM	7.	MANAGEMENT'S	DISCUSSION	&	ANALYSIS	(MD&A)

Financial	Accounting	Aspects

U.S.	Tax	Accommodation

In	2020,	the	FASB	issued	ASU	2020-04,	“Facilitation	of	the	
Effects	of	Reference	Rate	Reform	on	Financial	Reporting,”	
which	provides	several	optional	expedients	and	
exceptions	to	ease	the	potential	burden	in	accounting	for	
reference	rate	reform.	The	scope	of	ASU	2020-04	was	
expanded	in	2021	with	ASU	2021-01,	"Scope".	Refer	to	the	
Accounting	Changes	Issued	but	Not	Currently	Effective	
section	of	Note	1	-	Significant	Accounting	Policies	for	
additional	information.	

In	December	2021,	the	FASB	voted	to	extend	the	relief	
under	Topic	848	(Reference	Rate	Reform)	by	two	years,	
from	December	31,	2022	to	December	31,	2024.	

On	December	30,	2021,	the	IRS	released	final	guidance	
that	is	intended	to	facilitate	the	transition	of	existing	
contracts	from	LIBOR	to	new	reference	rates	without	
triggering	modification	accounting	or	taxable	exchange	
treatment	for	those	contracts.	This	guidance	specifies	
what	must	be	met	in	order	to	qualify	for	the	beneficial	
transition	approach	and	FHN	is	considering	this	guidance	
in	its	transition	plans.

Critical Accounting Policies & Estimates

Allowance for Loan and Lease Losses

Management’s	policy	is	to	maintain	the	ALLL	at	a	level	
sufficient	to	absorb	expected	credit	losses	in	the	loan	and	
lease	portfolio.	Management	performs	periodic	and	
systematic	detailed	reviews	of	its	loan	and	lease	portfolio	
to	identify	trends	and	to	assess	the	overall	collectability	of	
the	portfolio.	Management	believes	the	accounting	
estimate	related	to	the	ALLL	is	a	“critical	accounting	
estimate”	as:	(1)	changes	in	it	can	materially	affect	the	
provision	for	loan	and	lease	losses	and	net	income,	(2)	it	
requires	management	to	predict	borrowers’	likelihood	or	
capacity	to	repay,	including	evaluation	of	inherently	
uncertain	future	economic	conditions,	(3)	prepayment	
activity	must	be	projected	to	estimate	the	life	of	loans	
that	often	are	shorter	than	contractual	terms,	(4)	it	
requires	estimation	of	a	reasonable	and	supportable	
forecast	period	for	credit	losses	for	loan	portfolio	
segments	before	reversion	to	historical	loss	levels	over	the	
remaining	life	of	a	loan	and	(5)	expected	future	recoveries	
of	amounts	previously	charged	off	must	be	estimated.	
Accordingly,	this	is	a	highly	subjective	process	and	
requires	significant	judgment	since	it	is	difficult	to	
evaluate	current	and	future	economic	conditions	in	
relation	to	an	overall	credit	cycle	and	estimate	the	timing	
and	extent	of	loss	events	that	are	expected	to	occur	prior	
to	end	of	a	loan’s	and	leases's	estimated	life.	

FHN	believes	that	the	principal	assumptions	underlying	
the	accounting	estimates	made	by	management	include:	
(1)	the	commercial	loan	portfolio	has	been	properly	risk	
graded	based	on	information	about	borrowers	in	specific	
industries	and	specific	issues	with	respect	to	single	
borrowers;	(2)	borrower	specific	information	made	
available	to	FHN	is	current	and	accurate;	(3)	the	loan	
portfolio	has	been	segmented	properly	and	individual	
loans	have	similar	credit	risk	characteristics	and	will	
behave	similarly;	(4)	the	lives	for	loan	portfolio	pools	have	
been	estimated	properly,	including	consideration	of	
expected	prepayments;	(5)	the	economic	forecasts	utilized	

and	associated	weighting	selected	by	management	in	the	
modeling	of	expected	credit	losses	are	reflective	of	future	
economic	conditions;	(6)	entity-specific	historical	loss	
information	has	been	properly	assessed	for	all	loan	
portfolio	segments	as	the	initial	basis	for	estimating	
expected	credit	losses;	(7)	the	reasonable	and	supportable	
periods	for	loan	portfolio	segments	have	been	properly	
determined;	(8)	the	reversion	methodologies	and	
timeframes	for	migration	from	the	reasonable	and	
supportable	period	to	the	use	of	historical	loss	rates	are	
reasonable;	(9)	expected	recoveries	of	prior	charge	off	
amounts	have	been	properly	estimated;	and	
(10)	qualitative	adjustments	to	modeled	loss	results	
reasonably	reflect	expected	future	credit	losses	as	of	the	
date	of	the	financial	statements.

While	management	uses	the	best	information	available	to	
establish	the	ALLL,	future	adjustments	to	the	ALLL	and	
methodology	may	be	necessary	if	economic	or	other	
conditions	differ	substantially	from	the	assumptions	used	
in	making	the	estimates.	Such	adjustments	to	prior	
estimates,	as	necessary,	are	made	in	the	period	in	which	
these	factors	and	other	relevant	considerations	indicate	
that	loss	levels	vary	from	previous	estimates.

Selection	and	weighting	of	macroeconomic	forecasts	are	
the	most	significant	inputs	in	quantitative	ALLL	
calculations.	Due	to	the	sensitivity	of	the	ALLL	
determination	to	macroeconomic	forecasts,	changes	in	
those	forecasts	can	result	in	materially	different	results	
between	reporting	periods.	In	the	determination	of	the	
ALLL	as	of	December	31,	2021,	FHN	utilized	Moody's	
Baseline,	S1	(more	favorable)	and	S3	(adverse)	scenarios	
for	the	calculation	of	the	ALLL.		FHN	placed	the	most	
weight	on	Moody's	Baseline	scenario	but	also	included	
weightings	for	S1	and	S3	scenarios,	primarily	to	reflect	the	
uncertainty	of	macroeconomic	forecasts	related	to	the	
ongoing	economic	impacts	from	the	COVID-19	pandemic.		

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Due	to	the	dynamic	relationship	of	macroeconomic	inputs	
in	modeling	calculations,	quantifying	the	effects	of	
changing	individual	inputs	is	highly	challenging.		
Additionally,	management	applies	judgment	in	developing	
qualitative	adjustments	that	are	considered	necessary	to	
appropriately	reflect	elements	of	credit	risk	that	are	not	
captured	in	the	quantitative	model	results.		To	provide	
some	hypothetical	sensitivity	analysis,	FHN	prepared	two	
alternate	quantitative	calculations,	applying	100%	
weighting	to	Moody's	Baseline	and	S3	(adverse)	scenarios.		

Income Taxes

FHN	is	subject	to	the	income	tax	laws	of	the	U.S.	and	the	
states	and	jurisdictions	in	which	it	operates.	FHN	accounts	
for	income	taxes	in	accordance	with	ASC	740,	"Income	
Taxes".	Significant	judgments	and	estimates	are	required	
in	the	determination	of	the	consolidated	income	tax	
expense.	FHN	income	tax	expense,	deferred	tax	assets	and	
liabilities,	and	liabilities	for	unrecognized	tax	benefits	
reflect	management’s	best	estimate	of	current	and	future	
taxes	to	be	paid.	

Income	tax	expense	consists	of	both	current	and	deferred	
taxes.	Current	income	tax	expense	is	an	estimate	of	taxes	
to	be	paid	or	refunded	for	the	current	period	and	includes	
income	tax	expense	related	to	uncertain	tax	positions.	A	
DTA	or	a	DTL	is	recognized	for	the	tax	consequences	of	
temporary	differences	between	the	financial	statement	
carrying	amounts	and	the	tax	bases	of	existing	assets	and	
liabilities.	Deferred	taxes	can	be	affected	by	changes	in	tax	
rates	applicable	to	future	years,	either	as	a	result	of	
statutory	changes	or	business	changes	that	may	change	
the	jurisdictions	in	which	taxes	are	paid.	Additionally,	
DTAs	are	subject	to	a	“more	likely	than	not”	test	to	
determine	whether	the	full	amount	of	the	DTAs	should	be	
realized	in	the	financial	statements.	FHN	evaluates	the	
likelihood	of	realization	of	the	DTA	based	on	both	positive	
and	negative	evidence	available	at	the	time,	including	(as	
appropriate)	scheduled	reversals	of	DTLs,	projected	future	
taxable	income,	tax	planning	strategies,	and	recent	
financial	performance.	Realization	is	dependent	on	
generating	sufficient	taxable	income	prior	to	the	
expiration	of	the	carryforwards	attributable	to	or	
generated	with	respect	to	the	DTA.	In	projecting	future	
taxable	income,	FHN	incorporates	assumptions	including	
the	amount	of	future	state	and	federal	pretax	operating	
income,	the	reversal	of	temporary	differences,	and	the	

Contingent Liabilities

A	liability	is	contingent	if	the	amount	or	outcome	is	not	
presently	known,	but	may	become	known	in	the	future	as	
a	result	of	the	occurrence	of	some	uncertain	future	event.	
FHN	estimates	its	contingent	liabilities	based	on	
management’s	estimates	about	the	probability	of	
outcomes	and	their	ability	to	estimate	the	range	of	
exposure.	Accounting	standards	require	that	a	liability	be	
recorded	if	management	determines	that	it	is	probable	

These	hypothetical	calculations	resulted	in	a	2.5%	
reduction	and	17.5%	increase,	respectively,	in	ALLL	in	
comparison	to	the	ALLL	recorded	at	December	31,	2021,	
inclusive	of	qualitative	adjustments	that	are	affected	by	
the	weighting	of	forecast	scenarios.		

See	Note	1	-	Significant	Accounting	Policies	and	Note	5	-	
Allowance	for	Credit	Losses	for	detail	regarding	FHN’s	
processes,	models,	and	methodology	for	determining	the	
ALLL.

implementation	of	feasible	and	prudent	tax	planning	
strategies.	These	assumptions	require	significant	
judgment	about	the	forecasts	of	future	taxable	income	
and	are	consistent	with	the	plans	and	estimates	used	to	
manage	the	underlying	business.	If	the	“more	likely	than	
not”	test	is	not	met,	a	valuation	allowance	must	be	
established	against	the	DTA.

The	income	tax	laws	of	the	jurisdictions	in	which	FHN	
operate	are	complex	and	subject	to	different	
interpretations	by	the	taxpayer	and	the	relevant	
government	taxing	authorities.	In	determining	if	a	tax	
position	should	be	recognized	and	in	establishing	a	
provision	for	income	tax	expense,	FHN	must	make	
judgments	and	interpretations	about	the	application	of	
these	inherently	complex	tax	laws.	Interpretations	may	be	
subjected	to	review	during	examination	by	taxing	
authorities	and	disputes	may	arise	over	the	respective	tax	
positions.	FHN	attempts	to	resolve	disputes	that	may	arise	
during	the	tax	examination	and	audit	process.	However,	
certain	disputes	may	ultimately	be	resolved	through	the	
federal	and	state	court	systems.

FHN	monitors	relevant	tax	authorities	and	revises	
estimates	of	accrued	income	taxes	on	a	quarterly	basis.	
Changes	in	estimates	may	occur	due	to	changes	in	income	
tax	laws	and	their	interpretation	by	the	courts	and	
regulatory	authorities.	Revisions	of	estimates	may	also	
result	from	income	tax	planning	and	from	the	resolution	
of	income	tax	controversies.	Revisions	in	estimates	may	
be	material	to	operating	results	for	any	given	period.

See	Note	15	-	Income	Taxes	for	additional	information	
including	discussion	of	valuation	allowances	related	to	
deferred	tax	assets	and	the	potential	impact	of	
unrecognized	tax	benefits	on	future	earnings.

that	a	loss	has	occurred	and	the	loss	can	be	reasonably	
estimated.	In	addition,	it	must	be	probable	that	the	loss	
will	be	confirmed	by	some	future	event.	As	part	of	the	
estimation	process,	management	is	required	to	make	
assumptions	about	matters	that	are	by	their	nature	highly	
uncertain	and	difficult	to	estimate.

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The	assessment	of	contingent	liabilities,	including	legal	
contingencies,	involves	the	use	of	critical	estimates,	
assumptions,	and	judgments.	Management’s	estimates	
are	based	on	their	belief	that	future	events	will	validate	
the	current	assumptions	regarding	the	ultimate	outcome	
of	these	exposures.	However,	there	can	be	no	assurance	
that	future	events,	such	as	court	decisions	or	decisions	of	
arbitrators,	will	not	differ	from	management’s	
assessments.	Whenever	practicable,	management	
consults	with	third-party	experts	(e.g.,	attorneys,	
accountants,	claims	administrators,	etc.)	to	assist	with	the	

gathering	and	evaluation	of	information	related	to	
contingent	liabilities.	Based	on	internally	and/or	externally	
prepared	evaluations,	management	makes	a	
determination	whether	the	potential	exposure	requires	
accrual	in	the	financial	statements.

See	Note	17	-	Contingencies	and	Other	Disclosures	for	
additional	information	regarding	FHN's	existing	material	
contingent	liabilities,	including	those	with	and	without	loss	
accruals,	and	discussion	of	reasonably	possible	loss	
amounts	for	pending	litigation	matters.

Accounting Changes with Extended Transition Periods

Refer	to	Note	1	–	Significant	Accounting	Policies	for	a	
detail	of	accounting	changes	with	extended	transition	

periods,	which	section	is	incorporated	into	this	MD&A	by	
this	reference.

Non-GAAP Information

Certain	measures	are	included	in	this	report	are	“non-
GAAP”,	meaning	they	are	not	presented	in	accordance	
with	U.S.	GAAP	and	also	are	not	codified	in	U.S.	banking	
regulations	currently	applicable	to	FHN.	Although	other	
entities	may	use	calculation	methods	that	differ	from	
those	used	by	FHN	for	non-GAAP	measures,	FHN’s	
management	believes	such	measures	are	relevant	to	
understanding	the	capital	position	or	financial	results	of	
FHN	and	its	business	segments.	Non-GAAP	measures	are	
reported	to	FHN’s	management	and	Board	of	Directors	
through	various	internal	reports.

The	non-GAAP	measures	presented	in	this	report	are:	pre-
provision	net	revenue,	return	on	average	tangible	
common	equity,	tangible	common	equity	to	tangible	
assets,	adjusted	tangible	common	equity	to	risk-weighted	
assets,	tangible	book	value	per	common	share,	and	loans	
and	leases	excluding	PPP	loans.	Table	7.30	appearing	in	
the	MD&A	(Item	7	of	Part	II)	of	this	report	provides	a	
reconciliation	of	non-GAAP	items	presented	in	this	report	
to	the	most	comparable	GAAP	presentation.	

Presentation	of	regulatory	measures,	even	those	which	
are	not	GAAP,	provide	a	meaningful	base	for	

Table	7.30

comparability	to	other	financial	institutions	subject	to	the	
same	regulations	as	FHN,	as	demonstrated	by	their	use	by	
banking	regulators	in	reviewing	capital	adequacy	of	
financial	institutions.	Although	not	GAAP	terms,	these	
regulatory	measures	are	not	considered	“non-GAAP”	
under	U.S.	financial	reporting	rules	as	long	as	their	
presentation	conforms	to	regulatory	standards.	
Regulatory	measures	used	in	this	MD&A	include:	common	
equity	tier	1	capital,	generally	defined	as	common	equity	
less	goodwill,	other	intangibles,	and	certain	other	required	
regulatory	deductions;	tier	1	capital,	generally	defined	as	
the	sum	of	core	capital	(including	common	equity	and	
instruments	that	cannot	be	redeemed	at	the	option	of	the	
holder)	adjusted	for	certain	items	under	risk	based	capital	
regulations;	and	risk-weighted	assets,	which	is	a	measure	
of	total	on-	and	off-balance	sheet	assets	adjusted	for	
credit	and	market	risk,	used	to	determine	regulatory	
capital	ratios.

The	following	table	provides	a	reconciliation	of	non-GAAP	
items	presented	in	this	MD&A	to	the	most	comparable	
GAAP	presentation:

(Dollars	in	millions;	shares	in	thousands)

Pre-provision	Net	Revenue	(Non-GAAP)

Net	interest	income	(GAAP)

Plus:	Noninterest	income	(GAAP)

Total	Revenues	(GAAP)

Less:	Noninterest	expense	(GAAP)

Pre-provision	Net	Revenue	(Non-GAAP)

Tangible	Common	Equity	(Non-GAAP)

(A)	Total	equity	(GAAP)

Less:	Noncontrolling	interest	(a)

NON-GAAP	TO	GAAP	RECONCILIATION

2021

2020

2019

$	 1,994	

$	 1,662	

$	 1,210	

1,076	

3,070	

2,096	

1,492	

3,154	

1,718	

654	

1,864	

1,233	

$	

974	

$	 1,436	

$	

631	

$	 8,494	

$	 8,307	

$	 5,076	

295	

295	

295	

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Less:	Preferred	stock	(a)

(B)	Total	common	equity

Less:	Goodwill	and	other	intangible	assets	(GAAP)	(b)

(C)	Tangible	common	equity	(Non-GAAP)

Less:	Unrealized	gains	(losses)	on	AFS	securities,	net	of	tax

520	

7,679	

1,809	

5,870	

(36)	

470	

7,542	

1,865	

5,677	

108	

96	

4,685	

1,563	

3,122	

31	

(D)	Adjusted	tangible	common	equity	(Non-GAAP)

$	 5,906	

$	 5,569	

$	 3,091	

Tangible	Assets	(Non-GAAP)

(E)	Total	assets	(GAAP)

Less:	Goodwill	and	other	intangible	assets	(GAAP)	(b)

(F)	Tangible	assets	(Non-GAAP)

Average	Tangible	Common	Equity	(Non-GAAP)

Average	total	equity	(GAAP)

Less:	Average	noncontrolling	interest	(a)

Less:	Average	preferred	stock	(a)

(G)	Total	average	common	equity

Less:	Average	goodwill	and	other	intangible	assets	(GAAP)	(b)

(H)	Average	tangible	common	equity	(Non-GAAP)

Net	Income	Available	to	Common	Shareholders

(I)	Net	income	available	to	common	shareholders

Risk	Weighted	Assets	

(J)	Risk	weighted	assets	(c)

Period-end	shares	outstanding

(K)	Period-end	shares	outstanding	

Ratios

$	 89,092	

$	 84,209	

$	 43,311	

1,809	

1,865	

1,563	

$	 87,283	

$	 82,344	

$	 41,748	

$	 8,479	

$	 6,609	

$	 4,920	

295	

506	

7,678	

1,836	

295	

297	

6,017	

1,696	

295	

96	

4,529	

1,575	

$	 5,842	

$	 4,321	

$	 2,954	

$	

962	

$	

822	

$	

435	

$	 64,183	

$	 63,140	

$	 37,046	

	 533,577	

	 555,031	

	 311,469	

(A)/(E)	Total	period-end	equity	to	period-end	assets	(GAAP)

9.53	% 	

9.86	% 	

11.72	%

(C)/(F)	Tangible	common	equity	to	tangible	assets	(Non-GAAP)	

(D)/(J)	Adjusted	tangible	common	equity	to	risk	weighted	assets	(Non-GAAP)	

(I)/(G)	Return	on	average	common	equity	(GAAP)

(I)/(H)	Return	on	average	tangible	common	equity	(Non-GAAP)

6.73	

9.20	

12.53	

16.46	

6.89	

8.82	

13.66	

19.03	

7.48	

8.34	

9.60	

14.71	

(B)/(K)	Book	value	per	common	share	(GAAP)

$	 14.39	

$	 13.59	

$	 15.04	

(C)/(K)	Tangible	book	value	per	common	share	(Non-GAAP)

$	 11.00	

$	 10.23	

$	 10.02	

Loans	and	leases	excluding	PPP	loans	(Non-GAAP)
Commercial	loans	and	leases	excluding	PPP	loans

PPP	loans

Total	commercial	loans	and	leases

Total	consumer	loans

Total	loans	and	leases

(a) Included	in	total	equity	on	the	Consolidated	Balance	Sheets.
(b) Includes	goodwill	and	other	intangible	assets,	net	of	amortization.
(c) Defined	by	and	calculated	in	conformity	with	bank	regulations	applicable	to	FHN.	

$	 42,139	

$	 41,327	

1,038	

4,052	

	 43,177	

	 45,379	

	 11,682	

	 12,853	

$	 54,859	

$	 58,232	

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ITEM	7A.	QUANTITATIVE	&	QUALITATIVE	DISCLOSURES	ABOUT	MARKET	RISK

Item 7A. Quantitative and Qualitative Disclosures 

About Market Risk

The	information	called	for	by	this	Item	is	incorporated	
herein	by	reference	to:	2021	MD&A	(Item	7),	which	begins	
on	page	60	of	this	report;	Note	22-Derivatives,	which	
begins	on	page	184	of	this	report;	and	Note	23-Master	
Netting	and	Similar	Agreements	-	Repurchase,	Reverse	
Repurchase,	and	Securities	Borrowing	Transactions,	which	
begins	on	page	191	of	this	report.	Within	2021	MD&A,	

these	sections	are	especially	pertinent	to	this	Item	7A:	
Market	Risk	Management	and	Interest	Rate	Risk	
Management	which	begin,	respectively,	on	pages	91	and	
93	of	this	report.	Notes	22	and	23	are	part	of	our	2021	
Financial	Statements	(Item	8).	

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Table	of	Contents

ITEM	8		TOPICS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Item 8.  Financial Statements and 
Supplementary Data

TABLE	OF	ITEM	8	TOPICS

Report	of	Management	on	Internal	Control	Over	Financial	Reporting

Report	of	Independent	Registered	Public	Accounting	Firm

Balance	Sheets

Statements	of	Income

Statements	of	Comprehensive	Income

Statements	of	Changes	in	Equity

Statements	of	Cash	Flows

Notes	to	the	Consolidated	Financial	Statements

Note	1	Significant	Accounting	Policies

Note	2	Acquisitions	and	Divestitures

Note	3	Investment	Securities

Note	4	Loans	and	Leases

Note	5	Allowance	for	Credit	Losses

Note	6	Premises,	Equipment,	and	Leases

Note	7	Goodwill	and	Other	Intangible	Assets

Note	8	Mortgage	Banking	Activity

Note	9	Deposits

Note	10	Short-Term	Borrowings

Note	11	Term	Borrowings

Note	12	Preferred	Stock

Note	13	Regulatory	Capital	and	Restrictions	

Note	14	Components	of	Other	Comprehensive	Income	(Loss)

Note	15	Income	Taxes

Note	16	Earnings	Per	Share

Note	17	Contingencies	and	Other	Disclosures

Note	18	Retirement	Plans	and	Other	Employee	Benefits

Note	19	Stock	Options,	Restricted	Stock,	and	Dividend	Reinvestment	Plans

109

111

114

115

117

118

120

122

122

134

136

139

146

149

152

153

154

155

156

158

159

162

163

167

168

170

175

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ITEM	8		TOPICS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note	20	Business	Segment	Information

Note	21	Variable	Interest	Entities

Note	22	Derivatives

Note	23	Master	Netting	and	Similar	Agreements	-	Repurchase,	Reverse	Repurchase,	and	Securities	

Borrowing	Transactions

Note	24	Fair	Value	of	Assets	and	Liabilities

Note	25	Restructuring,	Repositioning,	and	Efficiency

Note	26	Parent	Company	Financial	Information

Note	27	Subsequent	Events

178

181

184

191

193

209

210

212

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Table	of	Contents

MANAGEMENT	REPORT	ON	ICOFR

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Report of Management on Internal Control over Financial Reporting

Management	at	First	Horizon	Corporation	is	responsible	for	establishing	and	maintaining	adequate	internal	control	over	
financial	reporting	as	defined	in	Rules	13a-15(f)	and	15d-15(f)	under	the	Securities	Exchange	Act	of	1934.	First	Horizon	
Corporation’s	internal	control	over	financial	reporting	is	a	process	designed	to	provide	reasonable	assurance	regarding	the	
reliability	of	financial	reporting	and	the	preparation	of	financial	statements	for	external	purposes	in	accordance	with	generally	
accepted	accounting	principles.

Even	effective	internal	controls,	no	matter	how	well	designed,	have	inherent	limitations	such	as	the	possibility	of	human	error	
or	of	circumvention	or	overriding	of	controls,	and	consideration	of	cost	in	relation	to	benefit	of	a	control.	Moreover,	
effectiveness	must	necessarily	be	considered	according	to	the	existing	state	of	the	art	of	internal	control.	Further,	because	of	
changes	in	conditions,	the	effectiveness	of	internal	controls	may	diminish	over	time.

Management	assessed	the	effectiveness	of	First	Horizon	Corporation’s	internal	control	over	financial	reporting	as	of	
December	31,	2021.	This	assessment	was	based	on	criteria	established	in	Internal	Control	–	Integrated	Framework	(2013)	
issued	by	the	Committee	of	Sponsoring	Organizations	of	the	Treadway	Commission	(COSO).

Based	on	our	assessment	and	those	criteria,	management	believes	that	First	Horizon	Corporation	maintained	effective	
internal	control	over	financial	reporting	as	of	December	31,	2021.

KPMG	LLP,	the	independent	registered	public	accounting	firm	that	audited	First	Horizon	Corporation's	financial	statements,	
issued	an	audit	report	on	First	Horizon	Corporation’s	internal	control	over	financial	reporting.	That	report	appears	on	the	
following	page.

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Table	of	Contents

OPINION	ON	ICOFR

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Report of Independent Registered Public Accounting Firm

To	the	Shareholders	and	Board	of	Directors
First	Horizon	Corporation:

Opinion	on	Internal	Control	Over	Financial	Reporting	

We	have	audited	First	Horizon	Corporation	and	subsidiaries'	(the	Company)	internal	control	over	financial	reporting	as	of	
December	31,	2021,	based	on	criteria	established	in	Internal	Control	–	Integrated	Framework	(2013)	issued	by	the	Committee	
of	Sponsoring	Organizations	of	the	Treadway	Commission.	In	our	opinion,	the	Company	maintained,	in	all	material	respects,	
effective	internal	control	over	financial	reporting	as	of	December	31,	2021,	based	on	criteria	established	in	Internal	Control	–	
Integrated	Framework	(2013)	issued	by	the	Committee	of	Sponsoring	Organizations	of	the	Treadway	Commission.

We	also	have	audited,	in	accordance	with	the	standards	of	the	Public	Company	Accounting	Oversight	Board	(United	States)	
(PCAOB),	the	consolidated	balance	sheets	of	the	Company	as	of	December	31,	2021	and	2020,	the	related	consolidated	
statements	of	income,	comprehensive	income,	changes	in	equity,	and	cash	flows	for	each	of	the	years	in	the	three-year	
period	ended	December	31,	2021,	and	the	related	notes	(collectively,	the	consolidated	financial	statements),	and	our	report	
dated	March	1,	2022	expressed	an	unqualified	opinion	on	those	consolidated	financial	statements.

Basis	for	Opinion	

The	Company’s	management	is	responsible	for	maintaining	effective	internal	control	over	financial	reporting	and	for	its	
assessment	of	the	effectiveness	of	internal	control	over	financial	reporting,	included	in	the	accompanying	Report	of	
Management	on	Internal	Control	Over	Financial	Reporting.	Our	responsibility	is	to	express	an	opinion	on	the	Company’s	
internal	control	over	financial	reporting	based	on	our	audit.	We	are	a	public	accounting	firm	registered	with	the	PCAOB	and	
are	required	to	be	independent	with	respect	to	the	Company	in	accordance	with	the	U.S.	federal	securities	laws	and	the	
applicable	rules	and	regulations	of	the	Securities	and	Exchange	Commission	and	the	PCAOB.

We	conducted	our	audit	in	accordance	with	the	standards	of	the	PCAOB.	Those	standards	require	that	we	plan	and	perform	
the	audit	to	obtain	reasonable	assurance	about	whether	effective	internal	control	over	financial	reporting	was	maintained	in	
all	material	respects.	Our	audit	of	internal	control	over	financial	reporting	included	obtaining	an	understanding	of	internal	
control	over	financial	reporting,	assessing	the	risk	that	a	material	weakness	exists,	and	testing	and	evaluating	the	design	and	
operating	effectiveness	of	internal	control	based	on	the	assessed	risk.	Our	audit	also	included	performing	such	other	
procedures	as	we	considered	necessary	in	the	circumstances.	We	believe	that	our	audit	provides	a	reasonable	basis	for	our	
opinion.

Definition	and	Limitations	of	Internal	Control	Over	Financial	Reporting	

A	company’s	internal	control	over	financial	reporting	is	a	process	designed	to	provide	reasonable	assurance	regarding	the	
reliability	of	financial	reporting	and	the	preparation	of	financial	statements	for	external	purposes	in	accordance	with	generally	
accepted	accounting	principles.	A	company’s	internal	control	over	financial	reporting	includes	those	policies	and	procedures	
that	(1)	pertain	to	the	maintenance	of	records	that,	in	reasonable	detail,	accurately	and	fairly	reflect	the	transactions	and	
dispositions	of	the	assets	of	the	company;	(2)	provide	reasonable	assurance	that	transactions	are	recorded	as	necessary	to	
permit	preparation	of	financial	statements	in	accordance	with	generally	accepted	accounting	principles,	and	that	receipts	and	
expenditures	of	the	company	are	being	made	only	in	accordance	with	authorizations	of	management	and	directors	of	the	
company;	and	(3)	provide	reasonable	assurance	regarding	prevention	or	timely	detection	of	unauthorized	acquisition,	use,	or	
disposition	of	the	company’s	assets	that	could	have	a	material	effect	on	the	financial	statements.

Because	of	its	inherent	limitations,	internal	control	over	financial	reporting	may	not	prevent	or	detect	misstatements.	Also,	
projections	of	any	evaluation	of	effectiveness	to	future	periods	are	subject	to	the	risk	that	controls	may	become	inadequate	
because	of	changes	in	conditions,	or	that	the	degree	of	compliance	with	the	policies	or	procedures	may	deteriorate.

Memphis,	Tennessee
March	1,	2022

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OPINION	ON	CONSOLIDATED	FINANCIAL	STATEMENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Report of Independent Registered Public Accounting Firm

To	the	Shareholders	and	Board	of	Directors	
First	Horizon	Corporation:

Opinion	on	the	Consolidated	Financial	Statements

We	have	audited	the	accompanying	consolidated	balance	sheets	of	First	Horizon	Corporation	and	subsidiaries	(the	Company)	
as	of	December	31,	2021	and	2020,	the	related	consolidated	statements	of	income,	comprehensive	income,	changes	in	
equity,	and	cash	flows	for	each	of	the	years	in	the	three-year	period	ended	December	31,	2021,	and	the	related	notes	
(collectively,	the	consolidated	financial	statements).	In	our	opinion,	the	consolidated	financial	statements	present	fairly,	in	all	
material	respects,	the	financial	position	of	the	Company	as	of	December	31,	2021	and	2020,	and	the	results	of	its	operations	
and	its	cash	flows	for	each	of	the	years	in	the	three-year	period	ended	December	31,	2021,	in	conformity	with	U.S.	generally	
accepted	accounting	principles.

We	also	have	audited,	in	accordance	with	the	standards	of	the	Public	Company	Accounting	Oversight	Board	(United	States)	
(PCAOB),	the	Company’s	internal	control	over	financial	reporting	as	of	December	31,	2021,	based	on	criteria	established	in	
Internal	Control	–	Integrated	Framework	(2013)	issued	by	the	Committee	of	Sponsoring	Organizations	of	the	Treadway	
Commission,	and	our	report	dated	March	1,	2022	expressed	an	unqualified	opinion	on	the	effectiveness	of	the	Company’s	
internal	control	over	financial	reporting.

Change	in	Accounting	Principle

As	discussed	in	Notes	1	and	5	to	the	consolidated	financial	statements,	the	Company	has	changed	its	method	of	accounting	
for	the	recognition	and	measurement	of	credit	losses	as	of	January	1,	2020	due	to	the	adoption	of	ASC	326,	Financial	
Instruments	—	Credit	Losses.

Basis	for	Opinion

These	consolidated	financial	statements	are	the	responsibility	of	the	Company’s	management.	Our	responsibility	is	to	express	
an	opinion	on	these	consolidated	financial	statements	based	on	our	audits.	We	are	a	public	accounting	firm	registered	with	
the	PCAOB	and	are	required	to	be	independent	with	respect	to	the	Company	in	accordance	with	the	U.S.	federal	securities	
laws	and	the	applicable	rules	and	regulations	of	the	Securities	and	Exchange	Commission	and	the	PCAOB.

We	conducted	our	audits	in	accordance	with	the	standards	of	the	PCAOB.	Those	standards	require	that	we	plan	and	perform	
the	audit	to	obtain	reasonable	assurance	about	whether	the	consolidated	financial	statements	are	free	of	material	
misstatement,	whether	due	to	error	or	fraud.	Our	audits	included	performing	procedures	to	assess	the	risks	of	material	
misstatement	of	the	consolidated	financial	statements,	whether	due	to	error	or	fraud,	and	performing	procedures	that	
respond	to	those	risks.	Such	procedures	included	examining,	on	a	test	basis,	evidence	regarding	the	amounts	and	disclosures	
in	the	consolidated	financial	statements.	Our	audits	also	included	evaluating	the	accounting	principles	used	and	significant	
estimates	made	by	management,	as	well	as	evaluating	the	overall	presentation	of	the	consolidated	financial	statements.	We	
believe	that	our	audits	provide	a	reasonable	basis	for	our	opinion.

Critical	Audit	Matter

The	critical	audit	matter	communicated	below	is	a	matter	arising	from	the	current	period	audit	of	the	consolidated	financial	
statements	that	was	communicated	or	required	to	be	communicated	to	the	audit	committee	and	that:	(1)	relates	to	accounts	
or	disclosures	that	are	material	to	the	consolidated	financial	statements	and	(2)	involved	our	especially	challenging,	
subjective,	or	complex	judgments.	The	communication	of	a	critical	audit	matter	does	not	alter	in	any	way	our	opinion	on	the	
consolidated	financial	statements,	taken	as	a	whole,	and	we	are	not,	by	communicating	the	critical	audit	matter	below,	
providing	a	separate	opinion	on	the	critical	audit	matter	or	on	the	accounts	or	disclosures	to	which	it	relates.

Assessment	of	the	allowance	for	loan	losses	for	loans	collectively	evaluated	for	impairment

As	discussed	in	Notes	1	and	5	to	the	consolidated	financial	statements,	the	Company’s	total	allowance	for	loan	losses	
as	of	December	31,	2021	was	$670	million,	of	which	a	portion	related	to	the	allowance	for	loan	losses	for	loans	

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OPINION	ON	CONSOLIDATED	FINANCIAL	STATEMENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

collectively	evaluated	for	impairment	(the	collective	ALLL).	The	collective	ALLL	includes	the	measure	of	expected	
credit	losses	on	a	collective	(pooled)	basis	for	those	loans	that	share	similar	risk	characteristics.	The	Company	
estimated	the	collective	ALLL	using	a	current	expected	credit	losses	methodology	which	is	based	on	relevant	
information	about	historical	experience,	current	conditions,	and	reasonable	and	supportable	forecasts	that	affect	the	
collectability	of	the	loan	balances.	The	expected	credit	losses	are	the	product	of	multiplying	the	Company’s	estimates	
of	probability	of	default	(PD),	loss	given	default	(LGD),	and	individual	loan	level	exposure	at	default	(EAD),	including	
amortization	and	prepayment	assumptions,	on	an	undiscounted	basis.	The	Company	uses	models	or	assumptions	to	
develop	expected	loss	forecasts,	which	incorporate	a	weighting	approach	for	multiple	macroeconomic	forecasts	over	
a	four	year	reasonable	and	supportable	forecast	period.	After	the	reasonable	and	supportable	forecast	period,	the	
Company	immediately	reverts	to	its	historical	loss	averages,	evaluated	over	the	historical	observation	periods,	for	the	
remaining	estimated	life	of	the	loans.	In	order	to	capture	the	unique	risks	of	the	loan	portfolio	within	the	PD,	LGD,	
and	prepayment	models,	the	Company	segments	the	portfolio	into	pools,	generally	incorporating	loan	grades	for	
commercial	loans.	The	Company	uses	qualitative	adjustments	to	adjust	historical	loss	information	in	situations	where	
current	loan	characteristics	differ	from	those	in	the	historical	loss	information	and	for	differences	in	economic	
conditions	and	other	factors.

We	identified	the	assessment	of	the	collective	ALLL	as	a	critical	audit	matter.	A	high	degree	of	audit	effort,	including	
specialized	skills	and	knowledge,	and	subjective	and	complex	auditor	judgment	was	involved	in	the	assessment	of	the	
collective	ALLL	due	to	significant	measurement	uncertainty.	Specifically,	the	assessment	encompassed	the	evaluation	
of	the	collective	ALLL	methodology,	including	the	methods	and	models	used	to	estimate	the	PD,	LGD,	and	
prepayments	and	their	significant	assumptions,	which	included	the	reasonable	and	supportable	forecast	period,	the	
economic	forecast	scenarios	and	macroeconomic	assumptions.	The	assessment	also	included	the	evaluation	of	
certain	qualitative	adjustments	and	their	significant	assumptions.	The	significant	assumptions	are	sensitive	to	
variation,	such	that	minor	changes	in	the	assumption	can	cause	significant	changes	in	the	estimates.	The	assessment	
also	included	an	evaluation	of	the	conceptual	soundness	and	performance	of	the	PD,	LGD,	and	prepayments	models.	
In	addition,	auditor	judgment	was	required	to	evaluate	the	sufficiency	of	audit	evidence	obtained.

The	following	are	the	primary	procedures	we	performed	to	address	this	critical	audit	matter.	We	evaluated	the	
design	and	tested	the	operating	effectiveness	of	certain	internal	controls	related	to	the	Company’s	measurement	of	
the	collective	ALLL	estimate,	including	controls	over	the:

•

•

•

•

•

assessment	of	the	collective	ALLL	methodology

performance	monitoring	of	the	PD,	LGD	and	prepayment	models	

continued	use	and	appropriateness	of	changes	to	the	PD,	LGD,	and	prepayment	models,	including	the	
significant	assumptions	used	in	the	PD,	LGD,	and	prepayment	models

development	of	the	qualitative	adjustments,	including	the	significant	assumptions	used	in	the	measurement	
of	the	qualitative	adjustments

analysis	of	the	collective	ALLL	results,	trends,	and	ratios.

We	evaluated	the	Company’s	process	to	develop	the	collective	ALLL	estimate	by	testing	certain	sources	of	data,	
factors,	and	assumptions	that	the	Company	used,	and	considered	the	relevance	and	reliability	of	such	data,	factors,	
and	assumptions.	In	addition,	we	involved	credit	risk	professionals	with	specialized	skills	and	knowledge,	who	
assisted	in:

•

•

•

evaluating	the	Company’s	collective	ALLL	methodology	for	compliance	with	U.S.	generally	accepted	
accounting	principles

evaluating	judgments	made	by	the	Company	relative	to	the	performance	testing	of	the	PD,	LGD,	and	
prepayment	models	by	comparing	them	to	relevant	Company-specific	metrics	and	trends	and	the	applicable	
industry	and	regulatory	practices

assessing	the	conceptual	soundness	and	performance	testing	of	the	PD,	LGD,	and	prepayment	models	by	
inspecting	the	model	documentation	to	determine	whether	the	models	are	suitable	for	their	intended	use

	 112

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OPINION	ON	CONSOLIDATED	FINANCIAL	STATEMENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

•

•

•

evaluating	the	selection	of	the	economic	forecast	scenarios	by	comparing	to	the	Company’s	business	
environment	and	relevant	industry	practices

evaluating	the	length	of	the	reasonable	and	supportable	forecast	period	by	comparing	to	specific	portfolio	
risk	characteristics	and	trends

evaluating	the	methodology	used	to	develop	the	qualitative	adjustments	and	the	effect	of	those	
adjustments	on	the	collective	ALLL	compared	with	relevant	credit	risk	factors	and	consistency	with	credit	
trends	and	identified	limitations	of	the	underlying	quantitative	models.

We	also	assessed	the	sufficiency	of	the	audit	evidence	obtained	related	to	the	collective	ALLL	estimate	by	evaluating	
the:

•

•

•

cumulative	results	of	the	audit	procedures

qualitative	aspects	of	the	Company’s	accounting	practice

potential	bias	in	the	accounting	estimates.

We	have	served	as	the	Company’s	auditor	since	2002.	

Memphis,	Tennessee
March	1,	2022

	 113

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Table	of	Contents

CONSOLIDATED	BALANCE	SHEETS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Consolidated Balance Sheets

(Dollars	in	millions,	except	per	share	amounts)

Assets
Cash	and	due	from	banks

Interest-bearing	deposits	with	banks

Federal	funds	sold	and	securities	purchased	under	agreements	to	resell

Trading	securities

Securities	available	for	sale	at	fair	value

Securities	held	to	maturity	(fair	value	of	$705	and	$10,	respectively)

Loans	held	for	sale	(including	$258	and	$405	at	fair	value,	respectively)

Loans	and	leases	(including	$—	and	$16	at	fair	value,	respectively)

Allowance	for	loan	and	lease	losses

Net	loans	and	leases

Premises	and	equipment

Goodwill

Other	intangible	assets

Other	assets

Total	assets

Liabilities
Noninterest-bearing	deposits

Interest-bearing	deposits

Total	deposits

Trading	liabilities

Short-term	borrowings

Term	borrowings

Other	liabilities

Total	liabilities

Equity
Preferred	stock,	Non-cumulative	perpetual,	no	par	value;	authorized	5,000,000	shares;	
issued	26,750	and	26,250	shares,	respectively
Common	stock,	$0.625	par	value;	authorized	700,000,000	shares;	issued	533,576,766	
and	555,030,652	shares,	respectively

Capital	surplus

Retained	earnings

Accumulated	other	comprehensive	loss,	net

FHN	shareholders'	equity

Noncontrolling	interest

Total	equity

Total	liabilities	and	equity

See	accompanying	notes	to	consolidated	financial	statements.

December	31,

2021

2020

$	

1,147	 $	

14,907	

641	

1,601	

8,707	

712	

1,172	

54,859	

(670)	
54,189	

665	

1,511	

298	

3,542	

1,203	

8,351	

445	

1,176	

8,047	

10	

1,022	

58,232	

(963)	
57,269	

759	

1,511	

354	

4,062	

$	

$	

89,092	 $	

84,209	

27,883	 $	
47,012	

74,895	

426	

2,124	

1,590	

1,563	

80,598	

520	

333	

4,743	

2,891	

(288)	

8,199	

295	

8,494	

22,173	

47,809	

69,982	

353	

2,198	

1,670	

1,699	

75,902	

470	

347	

5,074	

2,261	

(140)	

8,012	

295	

8,307	

$	

89,092	 $	

84,209	

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Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	INCOME

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Consolidated Statements of Income

(Dollars	in	millions,	except	per	share	data;	shares	in	thousands)

2021

2020

2019

Year	Ended	December	31

Interest	income

Interest	and	fees	on	loans	and	leases
Interest	and	fees	on	loans	held	for	sale

Interest	on	investment	securities

Interest	on	trading	securities

Interest	on	other	earning	assets

Total	interest	income
Interest	expense

Interest	on	deposits

Interest	on	trading	liabilities
Interest	on	short-term	borrowings
Interest	on	term	borrowings

Total	interest	expense
Net	interest	income
Provision	for	credit	losses
Net	interest	income	after	provision	for	credit	losses

Noninterest	income
Fixed	income

Deposit	transactions	and	cash	management

Mortgage	banking	and	title	income

Brokerage,	management	fees	and	commissions

Card	and	digital	banking	fees

Trust	services	and	investment	management

	Other	service	charges	and	fees

Securities	gains	(losses),	net

Purchase	accounting	gain

Other	income

Total	noninterest	income

Noninterest	expense
Personnel	expense
Net	occupancy	expense

Computer	software

Operations	services

Legal	and	professional	fees

Contract	employment	and	outsourcing

Amortization	of	intangible	assets

Equipment	expense

Communications	and	delivery

Advertising	and	public	relations

Impairment	of	long-lived	assets

Contributions

Other	expense

Total	noninterest	expense

Income	before	income	taxes

$	

1,957	 $	
33	

1,722	 $	
30	

121	

30

17
2,158	

81	

6	
5
72	

164	
1,994	

(310)	
2,304	

406	

175	

154	

88	

78	

51	

44	

13	

(1)	

68	

105	

35

6
1,898	

152	

6	
14
64	

236	
1,662	

503	
1,159	

423	

148	

129	

66	

60	

39	

26	

(6)	

533	

74	

1,076	

1,492	

1,210	
137	
116	

1,033	
116	
85	

80	

68	

67	

56	

47	

37

37

34	

14	

193

2,096	

1,284	

56	

84	

24	

40	

42	

31

18

7	

41	

141

1,718	

933	

1,394	
31	

121	

47

31
1,624	

307	

13	
41
53	

414	
1,210	

45	
1,165	

279	

132	

10	

55	

49	

30	

21	

—	

—	

78	

654	

695	
80	
61	

46	

72	

13	

25	

34	

25

34

23	

11	

114

1,233	

586	

	 115

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Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	INCOME

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Income	tax	expense

Net	income

Net	income	attributable	to	noncontrolling	interest

Net	income	attributable	to	controlling	interest

Preferred	stock	dividends

Net	income	available	to	common	shareholders

Basic	earnings	per	share

Diluted	earnings	per	share

Weighted	average	common	shares

Diluted	average	common	shares

See	accompanying	notes	to	consolidated	financial	statements.

274

76

1,010	 $	

857	 $	

11

12

999	 $	

845	 $	

37

962	 $	

1.76	 $	

1.74	 $	

23

822	 $	

1.90	 $	

1.89	 $	

$	

$	

$	

$	

$	

134

452	

11

441	

6

435	

1.39	

1.38	

546,354	

551,241	

432,125	

433,717	

313,637	

315,657	

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Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	COMPREHENSIVE	INCOME

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

 Consolidated Statements of Comprehensive Income

(Dollars	in	millions)
Net	income

Year	Ended	December	31

2021

2020

2019

$	

1,010	 $	

857	 $	

452	

Other	comprehensive	income	(loss),	net	of	tax:

Net	unrealized	gains	(losses)	on	securities	available	for	sale

Net	unrealized	gains	(losses)	on	cash	flow	hedges

Net	unrealized	gains	(losses)	on	pension	and	other	postretirement	plans

Other	comprehensive	income	(loss)

Comprehensive	income

Comprehensive	income	attributable	to	noncontrolling	interest

Comprehensive	income	attributable	to	controlling	interest

Income	tax	expense	(benefit)	of	items	included	in	other	comprehensive	
income:

Net	unrealized	gains	(losses)	on	securities	available	for	sale

Net	unrealized	gains	(losses)	on	cash	flow	hedges

Net	unrealized	gains	(losses)	on	pension	and	other	postretirement	plans

$	

$	

See	accompanying	notes	to	consolidated	financial	statements.

(144)	

(10)	

6	

(148)	

862	

11	

77	

9	

13	

99	

956	

12	

851	 $	

944	 $	

(46)	 $	

25	 $	

(3)	

2	

3	

3	

107	

15	

15	

137	

589	

11	

578	

35	

5	

5	

	 117

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Preferred	Stock

Common	Sock

Shares

Amount

Shares

Amount

Capital
Surplus

Retained	
Earnings

Accumulated
Other
Comprehensive
Income	(Loss)	
(a)

Noncontrolling	
Interest

Total

	 318,573	

$	

200	

$	 3,029	

$	 1,542	

$	

(376)	 $	

295	 $	 4,786	

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	CHANGES	IN	EQUITY

Consolidated Statements of Changes in Equity

(Dollars	in	millions,	except	per	share	data;	shares	in	
thousands)

Balance,	December	31,	2018

Adjustment	to	reflect	adoption	of	ASU	2016-02

Beginning	balance,	as	adjusted	

Net	income

Other	comprehensive	income	(loss)

Comprehensive	income	(loss)

Cash	dividends	declared:

Preferred	stock	

Common	stock	($.56	per	share)

Common	stock	repurchased	(b)

Common	stock	issued	for:

Stock	options	exercised	and	restricted	stock	awards

Stock-based	compensation	expense

Dividends	declared	-	noncontrolling	interest	of	
subsidiary	preferred	stock

Balance,	December	31,	2019

Adjustment	to	reflect	adoption	of	ASU	2016-13

Beginning	balance,	as	adjusted

Net	income

Other	comprehensive	income	(loss)

Comprehensive	income	(loss)

Cash	dividends	declared:

Preferred	stock

Common	stock	($.60	per	share)

Preferred	stock	issuance	(1,500	shares	issued	at	
$100,000	per	share	net	of	offering	costs)

Common	stock	repurchased	(b)

Common	stock	issued	for:

Stock	options	exercised	and	restricted	stock	awards

Net	income

Other	comprehensive	income	(loss)

Comprehensive	income	(loss)

Cash	dividends	declared:

Preferred	stock

Common	stock	($0.60	per	share)

Preferred	stock	issuance	(1,500	shares	issued	at	
$100,000	per	share	net	of	offering	costs)

Call	of	preferred	stock

Common	stock	repurchased	(b)

Common	stock	issued	for:

Stock	options	exercised	and	restricted	stock	awards

Stock-based	compensation	expense

Dividends	declared	-	noncontrolling	interest	of	
subsidiary	preferred	stock

1,000	

$	

—	

1,000	

—	

—	

—	

—	

—	

—	

—	

—	

—	

1,000	

—	

1,000	

—	

—	

—	

—	

—	

1,500	

—	

—	

96	

—	

96	

—	

—	

—	

—	

—	

—	

—	

—	

—	

96	

—	

96	

—	

—	

—	

—	

—	

144	

—	

—	

	 318,573	

—	

—	

—	

—	

—	

(9,100)	

1,996	

—	

—	

	 311,469	

—	

	 311,469	

—	

—	

—	

—	

—	

—	

(426)	

—	

1,726	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

1,500	

(1,000)	

145	

(95)	

—	

—	

—	

—	

—	

—	

—	

—	

200	

—	

—	

—	

—	

—	

(6)	

1	

—	

—	

195	

—	

195	

—	

—	

—	

—	

—	

—	

—	

—	

152	

—	

—	

—	

347	

—	

—	

—	

—	

—	

—	

—	

—	

(1)	

3,029	

1,541	

—	

—	

—	

—	

—	

(128)	

8	

22	

—	

441	

—	

441	

(6)	

(178)	

—	

—	

—	

—	

2,931	

1,798	

—	

(96)	

2,931	

1,702	

—	

—	

—	

—	

—	

—	

(4)	

7	

2,115	

32	

—	

(7)	

845	

—	

845	

(23)	

(263)	

—	

—	

—	

—	

—	

—	

—	

5,074	

2,261	

—	

—	

—	

—	

—	

—	

—	

999	

—	

999	

(32)	

(332)	

—	

(5)	

—	

—	

—	

—	

—	

—	

—	

—	

—	

(25,063)	

(16)	

(400)	

—	

—	

—	

3,609	

—	

—	

2	

—	

—	

26	

43	

—	

Issued	in	business	combination	(c)

	 23,750	

230	

	 243,015	

Stock-based	compensation	expense

Dividends	declared	-	noncontrolling	interest	of	
subsidiary	preferred	stock

Other	(d)

—	

—	

—	

—	

—	

—	

—	

—	

(753)	

Balance,	December	31,	2020

	 26,250	

470	

	 555,031	

—	

(376)	

—	

137	

137	

—	

—	

—	

—	

—	

—	

(239)	

—	

(239)	

—	

99	

99	

—	

—	

—	

—	

—	

—	

—	

—	

—	

(140)	

—	

(148)	

(148)	

—	

—	

—	

—	

—	

—	

—	

—	

—	

295	

11	

—	

11	

—	

—	

—	

—	

—	

(11)	

295	

—	

295	

12	

—	

12	

—	

—	

—	

—	

—	

—	

—	

(12)	

—	

295	

11	

—	

11	

—	

—	

—	

—	

—	

—	

—	

(1)	

4,785	

452	

137	

589	

(6)	

(178)	

(134)	

9	

22	

(11)	

5,076	

(96)	

4,980	

857	

99	

956	

(23)	

(263)	

144	

(4)	

7	

2,497	

32	

(12)	

(7)	

8,307	

1,010	

(148)	

862	

(32)	

(332)	

145	

(100)	

(416)	

28	

43	

(11)	

(11)	

Balance,	December	31,	2021

	 26,750	

$	

520	

	 533,577	

$	

333	

$	 4,743	

$	 2,891	

$	

(288)	 $	

295	 $	 8,494	

	 118

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Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	CHANGES	IN	EQUITY

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(a) Due	to	the	nature	of	the	preferred	stock	issued	by	FHN	and	its	subsidiaries,	all	components	of	other	comprehensive	income	(loss)	have	been	attributed	

solely	to	FHN	as	the	controlling	interest	holder.

(b) 2021,	2020,	and	2019	include	$401	million,	$4	million,	and	$130	million,	respectively,	repurchased	under	share	repurchase	programs.
(c) See	Note	2-	Acquisitions	and	Divestitures	for	additional	information.
(d) Represents	shares	canceled	in	connection	with	the	resolution	of	remaining	CBF	dissenters'	appraisal	process	and	to	cover	taxes	on	the	IBKC	equity	

compensation	grants	that	automatically	vested	as	part	of	the	merger.

See	accompanying	notes	to	consolidated	financial	statements.

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	CASH	FLOWS

Consolidated Statements of Cash Flows

(Dollars	in	millions)	
Operating	Activities
Net	income
Adjustments	to	reconcile	net	income	to	net	cash	provided	by	(used	in)	
operating	activities:

Provision	for	credit	losses
Deferred	income	tax	expense	(benefit)
Depreciation	and	amortization	of	premises	and	equipment
Amortization	of	intangible	assets
Net	other	amortization	and	accretion
Net	(increase)	decrease	in	trading	securities
Net	(increase)	decrease	in	derivatives
Purchase	accounting	gain
Stock-based	compensation	expense
Securities	(gains)	losses,	net
Loss	on	debt	extinguishment
Net	(gains)	losses	on	sale/disposal	of	fixed	assets
(Gain)	loss	on	BOLI

Loans	held	for	sale:

Purchases	and	originations
Gross	proceeds	from	settlements	and	sales
(Gain)	loss	due	to	fair	value	adjustments	and	other

Other	operating	activities,	net
Total	adjustments
Net	cash	provided	by	(used	in)	operating	activities
Investing	Activities
Proceeds	from	sales	of	securities	available	for	sale
Proceeds	from	maturities	of	securities	available	for	sale
Purchases	of	securities	available	for	sale
Purchases	of	securities	held	to	maturity
Proceeds	from	prepayments	of	securities	held	to	maturity	
Proceeds	from	sales	of	premises	and	equipment
Purchases	of	premises	and	equipment
Proceeds	from	sales	and	pay	downs	of	loans	classified	as	held	to	maturity
Proceeds	from	BOLI
Net	(increase)	decrease	in	loans	and	leases
Net	(increase)	decrease	in	interest-bearing	deposits	with	banks
Cash	(paid)	received	for	acquisitions,	net
Other	investing	activities,	net
Net	cash	provided	by	(used	in)	investing	activities
Financing	Activities
Common	stock:
Stock	options	exercised
Cash	dividends	paid
Repurchase	of	shares

Cancellation	of	common	shares

Preferred	stock	issuance

Call	of	preferred	stock

Cash	dividends	paid	-	preferred	stock	-	noncontrolling	interest

Year	Ended	December	31
2020

2019

2021

$	

1,010	 $	

857	 $	

452	

(310)	
—	
61	
56	
(67)	
1,824	
412	
1	
43	
(13)	
26	
29	
(8)	

(6,644)	
4,451	
(205)	
75	
(269)	
741	

68	
2,771	
(3,736)	
(720)	
17	
42	
(53)	
—	
22	
3,509	
(6,556)	
—	
19	
(4,617)	

28	
(333)	

(416)	

—	

145	

(100)	  

(11)	

503	
(18)	
52	
40	
(30)	
1,912	
(223)	
(533)	
32	
6	
—	
8	
(5)	

(4,710)	
2,907	
(81)	
(545)	
(685)	
172	

629	
4,099	
(4,740)	
—	
—	
12	
(58)	
—	
12	
(819)	
(6,187)	
2,071	
14	
(4,967)	

7	
(222)	

(4)	

(7)	

144	

— 

(12)	

45	
14	
44	
25	
(3)	
1,423	
(134)	
—	
22	
—	
—	
22	
(5)	

(2,075)	
818	
(7)	
189	
378	
830	

192	
800	
(630)	
—	
—	
20	
(49)	
20	
14	
(3,570)	
795	
—	
18	
(2,390)	

9	
(171)	

(134)	

—	

—	

— 

(11)	

	 120

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
 
	
	
	
    
Table	of	Contents

CONSOLIDATED	STATEMENTS	OF	CASH	FLOWS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Cash	dividends	paid	-	preferred	stock

Net	increase	(decrease)	in	deposits

Net	increase	(decrease)	in	short-term	borrowings

Increases	(decreases)	in	term	borrowings

Net	cash	provided	by	(used	in)	financing	activities
Net	increase	(decrease)	in	cash	and	cash	equivalents

Cash	and	cash	equivalents	at	beginning	of	period

Cash	and	cash	equivalents	at	end	of	period
Supplemental	Disclosures

Total	interest	paid

Total	taxes	paid

Total	taxes	refunded

Transfer	from	loans	to	OREO

Transfer	from	loans	HFS	to	trading	securities

Transfer	from	loans	to	loans	HFS

See	accompanying	notes	to	consolidated	financial	statements.

(33)	

4,919	

(75)	

(108)	

4,016	

140	

1,648	
1,788	 $	

170	 $	
258	

30	

4	

2,232	

31	

(17)	

7,143	

(1,529)	

(327)	

5,176	

381	

1,267	

1,648	 $	

261	 $	

105	

36	

2	

1,742	

9	

(6)	

(253)	

2,384	

(396)	

1,422	

(138)	

1,405	

1,267	

411	

71	

28	

9	

1,321	

31	

$	

$	

	 121

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table of Contents

NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

Notes to the Consolidated Financial Statements 

Note 1—Significant Accounting Policies

Basis	of	Accounting

The	consolidated	financial	statements	of	FHN,	including	its	
subsidiaries,	have	been	prepared	in	conformity	with	
accounting	principles	generally	accepted	in	the	United	
States	of	America	and	follow	general	practices	within	the	
industries	in	which	it	operates.	This	preparation	requires	
management	to	make	estimates	and	assumptions	that	
affect	the	amounts	reported	in	the	financial	statements	
and	accompanying	notes.	These	estimates	and	
assumptions	are	based	on	information	available	as	of	the	
date	of	the	financial	statements	and	could	differ	from	
actual	results.	

from	transaction-based	fees	is	generally	recognized	
immediately	upon	completion	of	the	transaction.	
Noninterest	income	from	service-based	fees	is	generally	
recognized	over	the	period	in	which	FHN	provides	the	
service.	Any	services	performed	over	time	generally	
require	that	FHN	render	services	each	period	and	
therefore	FHN	measures	progress	in	completing	these	
services	based	upon	the	passage	of	time	and	recognizes	
revenue	as	invoiced.

Following	is	a	discussion	of	FHN's	key	revenues	within	the	
scope	of	ASC	606,	"Revenue	from	Contracts	with	
Customers",	except	as	noted.

Merger	with	IBERIABANK	Corporation	

Fixed	Income

On	July	1,	2020,	FHN	and	IBERIABANK	Corporation	closed	
their	merger	of	equals	transaction.	Historical	periods	prior	
to	the	closing	of	the	merger	only	reflect	results	of	legacy	
FHN	operations.	Subsequent	to	closing,	results	reflect	all	
post-merger	activity.	Refer	to	Note	2	–	Acquisitions	and	
Divestitures	for	additional	information	regarding	the	
transaction.

Reclassification

In	connection	with	the	IBKC	merger,	certain	captions	in	
the	Consolidated	Balance	Sheets	and	Consolidated	
Statements	of	Income,	loan	categories,	and	business	
activities	within	the	segments	were	realigned.	Amounts	
reported	in	prior	periods'	consolidated	financial	
statements,	which	represent	FHN's	pre-merger	financial	
results,	have	been	reclassified	to	conform	to	the	current	
presentation.

Principles	of	Consolidation

The	consolidated	financial	statements	include	the	
accounts	of	FHN	and	other	entities	in	which	it	has	a	
controlling	financial	interest.	Variable	Interest	Entities	for	
which	FHN	or	a	subsidiary	has	been	determined	to	be	the	
primary	beneficiary	are	also	consolidated.	Affiliates	for	
which	FHN	is	not	considered	the	primary	beneficiary	and	
in	which	FHN	does	not	have	a	controlling	financial	interest	
are	accounted	for	by	the	equity	method.	These	
investments	are	included	in	other	assets,	and	FHN’s	
proportionate	share	of	income	or	loss	is	included	in	
noninterest	income.	All	significant	intercompany	
transactions	and	balances	have	been	eliminated.

Revenues

Revenue	is	recognized	when	the	performance	obligations	
under	the	terms	of	a	contract	with	a	client	are	satisfied	in	
an	amount	that	reflects	the	consideration	FHN	expects	to	
be	entitled.	FHN	derives	a	significant	portion	of	its	
revenues	from	fee-based	services.	Noninterest	income	

Fixed	income	includes	fixed	income	securities	sales,	
trading,	and	strategies,	loan	sales	and	derivative	sales	
which	are	not	within	the	scope	of	revenue	from	contracts	
with	customers.	Fixed	income	also	includes	investment	
banking	fees	earned	for	services	related	to	underwriting	
debt	securities	and	performing	portfolio	advisory	services.	
FHN's	performance	obligation	for	underwriting	services	is	
satisfied	on	the	trade	date	while	advisory	services	is	
satisfied	over	time.

Mortgage	Banking	and	Title	Income

Mortgage	banking	and	title	income	includes	mortgage	
servicing	income,	title	income,	mortgage	loan	originations	
and	sales,	derivative	settlements,	as	well	as	any	changes	in	
fair	value	recorded	on	mortgage	loans	and	derivatives.	
Mortgage	banking	income	from	1)	sale	of	loans,	2)	
settlement	of	derivatives,	3)	changes	in	fair	value	of	loans,	
derivatives	and	servicing	rights	and	4)	servicing	of	loans	
are	not	within	the	scope	of	revenue	from	contracts	with	
customers.		Title	income	is	earned	when	FHN	fulfills	its	
performance	obligation	at	the	point	in	time	when	the	
services	are	completed.

Deposit	Transactions	and	Cash	Management

Deposit	transactions	and	cash	management	activities	
include	fees	for	services	related	to	consumer	and	
commercial	deposit	products	(such	as	service	charges	on	
checking	accounts),	cash	management	products	and	
services	such	as	electronic	transaction	processing	
(Automated	Clearing	House	and	Electronic	Data	
Interchange),	account	reconciliation	services,	cash	vault	
services,	lockbox	processing,	and	information	reporting	to	
large	corporate	clients.	FHN's	obligation	for	transaction-
based	services	is	satisfied	at	the	time	of	the	transaction	
when	the	service	is	delivered	while	FHN's	obligation	for	
service	based	fees	is	satisfied	over	the	course	of	each	
month.

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Table of Contents

NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Brokerage,	Management	Fees	and	Commissions

Statements	of	Cash	Flows

Brokerage,	management	fees	and	commissions	include	
fees	for	portfolio	management,	trade	commissions,	and	
annuity	and	mutual	fund	sales.	Asset-based	management	
fees	are	charged	based	on	the	market	value	of	the	client’s	
assets.	The	services	associated	with	these	revenues,	which	
include	investment	advice	and	active	management	of	
client	assets	are	generally	performed	and	recognized	over	
a	month	or	quarter.	Transactional	revenues	are	based	on	
the	size	and	number	of	transactions	executed	at	the	
client’s	direction	and	are	generally	recognized	on	the	
trade	date.

Trust	Services	and	Investment	Management

Trust	services	and	investment	management	fees	include	
investment	management,	personal	trust,	employee	
benefits,	and	custodial	trust	services.	Obligations	for	trust	
services	are	generally	satisfied	over	time	but	may	be	
satisfied	at	points	in	time	for	certain	activities	that	are	
transactional	in	nature.

Card	and	Digital	Banking	Fees

Card	and	digital	banking	fees	include	credit	interchange	
and	network	revenues	and	various	card-related	fees.	
Interchange	income	is	recognized	concurrently	with	the	
delivery	of	services	on	a	daily	basis.	Card-related	fees	such	
as	late	fees,	currency	conversion,	and	cash	advance	fees	
are	loan-related	and	excluded	from	the	scope	of	ASC	606.

Contract	Balances

As	of	December	31,	2021,	accounts	receivable	related	to	
products	and	services	on	non-interest	income	were	
$12	million.	For	the	year	ended	December	31,	2021,	FHN	
had	no	material	impairment	losses	on	non-interest	
accounts	receivable	and	there	were	no	material	contract	
assets,	contract	liabilities	or	deferred	contract	
costs	recorded	on	the	Consolidated	Balance	Sheets	as	of	
December	31,	2021.	Credit	risk	is	assessed	on	these	
accounts	receivable	each	reporting	period	and	the	amount	
of	estimated	uncollectible	receivables	is	not	material.

Transaction	Price	Allocated	to	Remaining	Performance	
Obligations

For	the	year	ended	December	31,	2021,	revenue	
recognized	from	performance	obligations	related	to	prior	
periods	was	not	material.	Revenue	expected	to	be	
recognized	in	any	future	year	related	to	remaining	
performance	obligations,	excluding	revenue	pertaining	to	
contracts	that	have	an	original	expected	duration	of	one	
year	or	less	and	contracts	where	revenue	is	recognized	as	
invoiced,	is	not	material.

Refer	to	Note	20	-	Business	Segment	Information	for	a	
reconciliation	of	disaggregated	revenue	by	major	product	
line	and	reportable	segment.

For	purposes	of	these	statements,	cash	and	due	from	
banks,	federal	funds	sold,	and	securities	purchased	under	
agreements	to	resell	are	considered	cash	and	cash	
equivalents.	Federal	funds	are	usually	sold	for	one-day	
periods,	and	securities	purchased	under	agreements	to	
resell	are	short-term,	highly	liquid	investments.	

Debt	Investment	Securities

Debt	securities	that	may	be	sold	prior	to	maturity	are	
classified	as	AFS	and	are	carried	at	fair	value.	The	
unrealized	gains	and	losses	on	debt	securities	AFS,	
including	securities	for	which	no	credit	impairment	exists,	
are	excluded	from	earnings	and	are	reported,	net	of	tax,	
as	a	component	of	other	comprehensive	income	within	
shareholders’	equity	and	the	Consolidated	Statements	of	
Comprehensive	Income.	Debt	securities	which	
management	has	the	intent	and	ability	to	hold	to	maturity	
are	reported	at	amortized	cost.	Interest	only	strips	were	
classified	in	securities	AFS	and	valued	at	elected	fair	value	
in	periods	prior	to	October	1,	2021	at	which	time	they	
were	transferred	to	trading	securities.	See	Note	24	-	Fair	
Value	of	Assets	and	Liabilities	for	additional	information.	
Realized	gains	and	losses	(i.e.,	from	sales)	for	debt	
investment	securities	are	determined	by	the	specific	
identification	method	and	reported	in	noninterest	income.

The	evaluation	of	credit	risk	for	HTM	debt	securities	
mirrors	the	process	described	below	for	loans	held	for	
investment.	AFS	debt	securities	are	reviewed	for	potential	
credit	impairment	at	the	individual	security	level.	The	
evaluation	of	credit	risk	includes	consideration	of	third-
party	and	government	guarantees	(both	explicit	and	
implicit),	senior	or	subordinated	status,	credit	ratings	of	
the	issuer,	the	effects	of	interest	rate	changes	since	
purchase	and	observable	market	information	such	as	
issuer-specific	credit	spreads.	Credit	losses	for	AFS	debt	
securities	are	generally	recognized	through	establishment	
of	an	allowance	for	credit	losses	that	cannot	exceed	the	
amount	by	which	amortized	cost	exceeds	fair	value.	
Charge-offs	are	recorded	as	reductions	of	the	security’s	
amortized	cost	and	the	credit	allowance.	Subsequent	
improvements	in	estimated	credit	losses	result	in	
reduction	of	the	credit	allowance,	but	not	beyond	zero.	
However,	if	FHN	has	the	intent	to	sell	or	if	it	is	more-likely-
than-not	that	it	will	be	compelled	to	sell	a	security	with	an	
unrecognized	loss,	the	difference	between	the	security's	
carrying	value	and	fair	value	is	recognized	through	
earnings	and	a	new	amortized	cost	basis	is	established	for	
the	security	(i.e.,	no	allowance	for	credit	losses	is	
recognized).

FHN	has	elected	to	exclude	accrued	interest	receivable	
from	the	fair	value	and	amortized	cost	basis	on	debt	
securities	when	assessing	whether	these	securities	have	
experienced	credit	impairment.	Additionally,	FHN	has	
elected	to	not	measure	an	allowance	for	credit	losses	on	
AIR	for	debt	securities	based	on	its	policy	to	write	off	

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Table of Contents

NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

uncollectible	interest	in	a	timely	manner,	which	generally	
occurs	when	delinquency	reaches	no	more	than	90	days	
for	all	security	types.	Any	such	write	offs	are	recognized	as	
a	reduction	of	interest	income.	AIR	for	debt	securities	is	
included	within	other	assets	in	the	Consolidated	Balance	
Sheet.

Equity	Investment	Securities

Equity	securities	are	classified	in	other	assets.	Banks	
organized	under	state	law	may	apply	to	be	members	of	
the	Federal	Reserve	System.	Each	member	bank	is	
required	to	own	stock	in	its	regional	Federal	Reserve	Bank.	
Given	this	requirement,	FRB	stock	may	not	be	sold,	
traded,	or	pledged	as	collateral	for	loans.	Membership	in	
the	Federal	Home	Loan	Bank	network	requires	ownership	
of	capital	stock.	Member	banks	are	entitled	to	borrow	
funds	from	the	FHLB	and	are	required	to	pledge	mortgage	
loans	as	collateral.	Investments	in	the	FHLB	are	non-
transferable	and,	generally,	membership	is	maintained	
primarily	to	provide	a	source	of	liquidity	as	needed.	FRB	
and	FHLB	stock	are	recorded	at	cost	and	are	subject	to	
impairment	reviews.	FHN's	subsidiary,	First	Horizon	Bank,	
was	a	state	member	bank	throughout	2021.	

Other	equity	investments	primarily	consist	of	mutual	
funds	which	are	marked	to	fair	value	through	earnings.	
Smaller	balances	of	equity	investments	without	a	readily	
determinable	fair	value	are	recorded	at	cost	minus	
impairment	with	adjustments	through	earnings	for	
observable	price	changes	in	orderly	transactions	for	the	
identical	or	a	similar	investment	of	the	same	issuer.

Fed	Funds	Sold	and	Purchased

Fed	funds	sold	and	purchased	represent	unsecured	
overnight	funding	arrangements	between	participants	in	
the	Federal	Reserve	system	primarily	to	assist	banks	in	
meeting	their	regulatory	cash	reserve	requirements.	Fed	
Funds	sold	are	evaluated	for	credit	risk	each	reporting	
period.	Due	to	the	short	duration	of	each	transaction	and	
the	history	of	no	credit	losses,	no	credit	loss	has	been	
recognized.

Securities	Purchased	Under	Agreements	to	Resell	and	
Securities	Sold	Under	Agreements	to	Repurchase

FHN	purchases	short-term	securities	under	agreements	to	
resell	which	are	accounted	for	as	collateralized	financings	
except	where	FHN	does	not	have	an	agreement	to	sell	the	
same	or	substantially	the	same	securities	before	maturity	
at	a	fixed	or	determinable	price.	All	of	FHN’s	securities	
purchased	under	agreements	to	resell	are	recognized	as	
collateralized	financings.	Securities	delivered	under	these	
transactions	are	delivered	to	either	the	dealer	custody	
account	at	the	FRB	or	to	the	applicable	counterparty.	
Securities	sold	under	agreements	to	repurchase	are	
offered	to	cash	management	clients	as	an	automated,	
collateralized	investment	account.	Securities	sold	under	
agreements	to	repurchase	are	also	used	by	the	consumer/
commercial	bank	to	obtain	favorable	borrowing	rates	on	

its	purchased	funds.	All	of	FHN's	securities	sold	under	
agreements	to	repurchase	are	secured	borrowings.	

Collateral	is	valued	daily	and	FHN	may	require	
counterparties	to	deposit	additional	securities	or	cash	as	
collateral,	or	FHN	may	return	cash	or	securities	previously	
pledged	by	counterparties,	or	FHN	may	be	required	to	
post	additional	securities	or	cash	as	collateral,	based	on	
the	contractual	requirements	for	these	transactions.

FHN’s	fixed	income	business	utilizes	securities	borrowing	
arrangements	as	part	of	its	trading	operations.	Securities	
borrowing	transactions	generally	require	FHN	to	deposit	
cash	with	the	securities	lender.	The	amount	of	cash	
advanced	is	recorded	within	securities	purchased	under	
agreements	to	resell	in	the	Consolidated	Balance	Sheets.	
These	transactions	are	not	considered	purchases	and	the	
securities	borrowed	are	not	recognized	by	FHN.	FHN	does	
not	conduct	securities	lending	transactions.

Securities	purchased	under	agreements	to	resell	and	
securities	borrowing	arrangements	are	evaluated	for	
credit	risk	each	reporting	period.	As	presented	in	Note	23	-	
Master	Netting	and	Similar	Agreements	-	Repurchase,	
Reverse	Repurchase,	and	Securities	Borrowing	
Transactions,	these	agreements	are	collateralized	by	the	
related	securities	and	collateral	maintenance	provisions	
with	counterparties,	including	replenishment	and	
adjustment	on	a	transaction	specific	basis.	This	collateral	
includes	both	the	securities	collateral	for	each	transaction	
as	well	as	offsetting	securities	sold	under	agreements	to	
repurchase	with	the	same	counterparty.	Given	the	history	
of	no	credit	losses	and	collateralized	nature	of	these	
transactions,	no	credit	loss	has	been	recognized.

Loans	Held	for	Sale

Loans	originated	or	purchased	for	which	management	
lacks	the	intent	to	hold	are	included	in	loans	held	for	sale	
in	the	Consolidated	Balance	Sheets.	FHN	generally	
accounts	for	loans	held	for	sale	at	the	lower	of	amortized	
cost	or	market	value,	with	an	exception	for	certain	
mortgage	loans	held	for	sale	and	repurchased	loans	that	
are	not	governmentally	insured	which	are	carried	under	
the	fair	value	option	of	reporting.

• Fair	Value	Option	Election.	These	loans	consist	of	
originated	fixed	rate	single-family	residential	
mortgage	loans	that	are	committed	to	be	sold	in	the	
secondary	market.	Gains	and	losses	on	these	
mortgage	loans	are	included	in	mortgage	banking	and	
title	income.

• Other	loans	held	for	sale.	For	these	loans,	gains	on	

sale	are	recognized	through	noninterest	income.	Net	
unrealized	losses,	if	any,	are	recognized	through	a	
valuation	allowance	that	is	also	recorded	as	a	charge	
to	noninterest	income.	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

Table of Contents

Loans	and	Leases

Generally,	loans	are	stated	at	principal	amounts	
outstanding,	net	of	unearned	income.	Interest	on	loans	is	
recognized	on	an	accrual	basis	at	the	applicable	interest	
rate	on	the	principal	amount	outstanding.	Loan	origination	
fees	and	direct	costs	as	well	as	premiums	and	discounts	
are	amortized	as	level	yield	adjustments	over	the	
respective	loan	terms.	Unamortized	net	fees	or	costs,	
premiums	and	discounts	are	recognized	in	interest	income	
upon	early	repayment	of	the	loans.	Loan	commitment	
fees	are	generally	deferred	and	amortized	on	a	straight-
line	basis	over	the	commitment	period.

Equipment	financing	leases	to	commercial	clients	are	
primarily	classified	as	direct	financing	and	sales-type	
leases.	Equipment	financing	leases	are	reported	at	the	net	
lease	investment,	which	represents	the	sum	of	minimum	
lease	payments	over	the	lease	term	and	the	estimated	
residual	value,	less	unearned	interest	income.	Interest	
income	is	accrued	as	earned	over	the	term	of	the	lease	
based	on	the	net	investment	in	leases.	Fees	incurred	to	
originate	the	lease	are	deferred	and	recognized	as	an	
adjustment	of	the	yield	on	the	lease.

FHN	has	elected	to	exclude	accrued	interest	receivable	
from	the	amortized	cost	basis	on	its	held-for-investment	
loan	portfolio.	FHN	has	also	elected	to	not	measure	an	
allowance	for	credit	losses	on	AIR	for	loans	held	for	
investment	based	on	its	policy	to	write	off	uncollectible	
interest	in	a	timely	manner,	which	occurs	when	a	loan	is	
placed	on	nonaccrual	status.	Such	write-offs	are	
recognized	as	a	reduction	of	interest	income.	AIR	for	held-
for-investment	loans	is	included	within	other	assets	in	the	
Consolidated	Balance	Sheets.

FHN	has	continued	to	accrue	interest	on	loans	for	which	
payment	deferrals	have	been	extended	to	borrowers	
affected	by	the	COVID-19	pandemic.	Deferrals	are	
typically	made	in	increments	of	three	or	six	months.	
Cumulative	deferrals	of	six	months	or	longer	are	beyond	
FHN's	normal	write-off	practices	for	accrued	interest.	
Therefore,	these	interest	deferrals	do	not	qualify	for	FHN's	
election	to	not	recognize	a	credit	loss	allowance	for	
accrued	interest.	Accordingly,	FHN	has	estimated	credit	
losses	for	COVID-19	interest	deferrals	which	is	included	
within	AIR	in	other	assets	in	the	Consolidated	Balance	
Sheets.

Nonaccrual	and	Past	Due	Loans

Generally,	loans	are	placed	on	nonaccrual	status	if	it	
becomes	evident	that	full	collection	of	principal	and	
interest	is	at	risk,	impairment	has	been	recognized	as	a	
partial	charge-off	of	principal	balance	due	to	insufficient	
collateral	value	and	past	due	status,	or	on	a	case-by-case	
basis	if	FHN	continues	to	receive	payments,	but	there	are	
other	borrower-specific	issues.	Consumer	loans	are	
generally	placed	into	nonaccrual	status	no	later	than	90	
days	past	due.	

• The	accrual	status	policy	for	commercial	TDRs	follows	
the	same	internal	policies	and	procedures	as	other	
commercial	portfolio	loans.	

• Residential	real	estate	loans	discharged	through	
Chapter	7	bankruptcy	and	not	reaffirmed	by	the	
borrower	(“discharged	bankruptcies”)	are	placed	on	
nonaccrual	and	are	reported	as	TDRs.	They	are	not	
returned	to	accrual	status	even	if	current	and	
performing	in	the	future.	

• Current	second	lien	residential	real	estate	loans	that	
are	junior	to	first	liens	are	placed	on	nonaccrual	
status	if	in	bankruptcy.

• Consumer	real	estate	(HELOC	and	residential	real	

estate	installment	loans),	if	not	already	on	nonaccrual	
per	above	situations,	are	placed	on	nonaccrual	if	the	
loan	is	30	or	more	days	delinquent	at	the	time	of	
modification	and	is	also	determined	to	be	a	TDR.

When	commercial	and	consumer	loans	within	each	
portfolio	segment	and	class	are	placed	on	nonaccrual	
status,	accrued	but	uncollected	interest	is	reversed	and	
charged	against	interest	income.	Management	may	elect	
to	continue	the	accrual	of	interest	when	the	estimated	net	
realizable	value	of	collateral	is	sufficient	to	recover	the	
principal	balance	and	accrued	interest.	Interest	payments	
received	on	nonaccrual	loans	are	normally	applied	to	
outstanding	principal	first.	Once	all	principal	has	been	
received,	additional	interest	payments	are	recognized	on	a	
cash	basis	as	interest	income.	

Generally,	commercial	and	consumer	loans	within	each	
portfolio	segment	and	class	that	have	been	placed	on	
nonaccrual	status	can	be	returned	to	accrual	status	if	all	
principal	and	interest	is	current	and	FHN	expects	full	
repayment	of	the	remaining	contractual	principal	and	
interest.	This	typically	requires	that	a	borrower	make	
payments	in	accordance	with	the	contractual	terms	for	a	
sustained	period	of	time	(generally	for	a	minimum	of	six	
months)	before	being	returned	to	accrual	status.	For	TDRs,	
FHN	may	also	consider	a	borrower’s	sustained	historical	
repayment	performance	for	a	reasonable	time	prior	to	the	
restructuring	in	assessing	whether	the	borrower	can	meet	
the	restructured	terms,	as	it	may	indicate	whether	the	
borrower	is	capable	of	servicing	the	level	of	debt	under	
the	modified	terms.

Residential	real	estate	loans	discharged	through	Chapter	7	
bankruptcy	and	not	reaffirmed	by	the	borrower	are	not	
returned	to	accrual	status.	For	current	second	liens	that	
have	been	placed	on	nonaccrual	because	the	first	lien	is	
90	or	more	days	past	due	or	is	a	TDR	or	bankruptcy,	the	
second	lien	may	be	returned	to	accrual	upon	pay-off	or	
cure	of	the	first	lien.

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NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

Table of Contents

Charge-offs

For	all	commercial	and	consumer	loan	portfolio	segments,	
all	losses	of	principal	are	charged	to	the	ALLL	in	the	period	
in	which	the	loan	is	deemed	to	be	uncollectible.

For	consumer	loans,	the	timing	of	a	full	or	partial	charge-
off	generally	depends	on	the	loan	type	and	delinquency	
status.	Generally,	for	the	consumer	real	estate	segment,	a	
loan	will	be	either	partially	or	fully	charged-off	when	it	
becomes	180	days	past	due.	At	this	time,	if	the	collateral	
value	does	not	support	foreclosure,	balances	are	fully	
charged-off	and	other	avenues	of	recovery	are	pursued.	If	
the	collateral	value	supports	foreclosure,	the	loan	is	
charged-down	to	net	realizable	value	(collateral	value	less	
estimated	costs	to	sell)	and	is	placed	on	nonaccrual	status.	
For	residential	real	estate	loans	discharged	in	Chapter	7	
bankruptcy	and	not	reaffirmed	by	the	borrower,	the	fair	
value	of	the	collateral	position	is	assessed	at	the	time	FHN	
is	made	aware	of	the	discharge	and	the	loan	is	charged	
down	to	the	net	realizable	value	(collateral	value	less	
estimated	costs	to	sell).	Within	the	credit	card	and	other	
portfolio	segment,	credit	cards	and	installment	loans	
secured	by	automobiles	are	normally	charged-off	upon	
reaching	180	days	past	due	while	other	non-real	estate	
consumer	loans	are	charged-off	upon	reaching	120	days	
past	due.

For	acquired	PCD	loans	where	all	or	a	portion	of	the	loan	
balance	had	been	charged	off	prior	to	acquisition,	and	for	
which	active	collection	efforts	are	still	underway,	the	ALLL	
recorded	at	acquisition	is	immediately	charged	off	if	
required	by	FHN’s	existing	charge	off	policy.	Additionally,	
FHN	is	required	to	consider	its	existing	policies	in	
determining	whether	to	charge	off	any	financial	assets,	
regardless	of	whether	a	charge-off	was	recorded	by	the	
predecessor	company.	The	initial	ALLL	recognized	on	PCD	
assets	includes	the	gross-up	of	the	loan	balance	reduced	
by	immediate	charge-offs	for	loans	previously	charged	off	
by	the	predecessor	company	or	which	meet	FHN’s	charge-
off	policy	on	the	date	of	acquisition.	Charge-offs	against	
the	allowance	related	to	such	acquired	PCD	loans	do	not	
result	in	an	income	statement	impact.

Purchased	Credit-Deteriorated	Loans

At	the	time	of	acquisition	FHN	evaluates	all	acquired	loans	
to	determine	if	they	have	experienced	a	more-than-
insignificant	deterioration	in	credit	quality	since	
origination.	PCD	loans	can	be	identified	on	either	an	1)	
individual	or	2)	pooled	basis	when	the	loans	share	similar	
risk	characteristics.	FHN	evaluates	various	absolute	factors	
to	assist	in	the	identification	of	PCD	loans,	including	
criteria	such	as,	existing	PCD	status,	risk	rating	of	special	
mention	or	lower,	nonaccrual	or	impaired	status,	
identification	of	prior	TDRs,	and	delinquency	status.	FHN	
also	utilizes	relative	factors	to	identify	PCD	loans	such	as	
commercial	loan	grade	migration,	expansion	of	borrower	
credit	spreads,	declines	in	external	risk	ratings	and	
changes	in	consumer	loan	characteristics	(e.g.,	FICO	

decline	or	LTV	increase).	In	addition,	factors	reflective	of	
broad	economic	considerations	are	also	considered	in	
identifying	PCD	loans.	These	include	industry,	collateral	
type,	and	geographic	location	for	the	borrower’s	
operations.	Internal	factors	for	origination	of	new	loans	
that	are	similar	to	the	acquired	loans	are	also	evaluated	to	
assess	loans	for	PCD	status,	including	increases	in	required	
yields,	necessity	of	borrowers’	providing	additional	
collateral	and/or	guarantees	and	changes	in	acceptable	
loan	duration.	Other	indicators	may	also	be	used	to	
evaluate	loans	for	PCD	status	depending	on	borrower-
specific	communications	and	actions,	such	public	
statements,	initiation	of	loan	modification	discussions	and	
obtaining	emergency	funding	from	alternate	sources.

Upon	acquisition,	the	expected	credit	losses	are	allocated	
to	the	purchase	price	of	individual	PCD	loans	to	determine	
each	individual	asset's	amortized	cost	basis,	typically	
resulting	in	a	reduction	of	the	discount	that	is	accreted	
prospectively	to	interest	income.	At	the	acquisition	date	
and	prospectively,	only	the	unpaid	principal	balance	is	
incorporated	within	the	estimation	of	expected	credit	
losses	for	PCD	loans.	Otherwise,	the	process	for	
estimation	of	expected	credit	losses	is	consistent	with	that	
discussed	below.	As	discussed	below	FHN	applies	
undiscounted	cash	flow	methodologies	for	the	estimation	
of	expected	credit	losses,	which	results	in	the	calculated	
amount	of	credit	losses	at	acquisition	that	is	added	to	the	
amortized	cost	basis	of	the	related	PCD	loans	to	exceed	
the	discounted	value	of	estimated	credit	losses	included	in	
the	loan	valuation.	

For	PCD	loans	where	all	or	a	portion	of	the	loan	balance	
has	been	previously	written-off,	or	would	be	subject	to	
write-off	under	FHN’s	charge-off	policy,	the	initial	ALLL	
included	as	part	of	the	grossed-up	loan	balance	at	
acquisition	was	immediately	written-off,	resulting	in	a	
zero	period-end	allowance	balance	and	no	impact	on	the	
ALLL	rollforward.

Allowance	for	Credit	Losses

The	nature	of	the	process	by	which	FHN	determines	the	
appropriate	ACL	requires	the	exercise	of	considerable	
judgment.	See	Note	5	-	Allowance	for	Credit	Losses	for	a	
discussion	of	FHN’s	ACL	methodology	and	a	description	of	
the	models	utilized	in	the	estimation	process	for	the	
commercial	and	consumer	loan	portfolios.	

Future	adjustments	to	the	ACL	may	be	necessary	if	
economic	or	other	conditions	differ	substantially	from	the	
assumptions	used	in	making	the	estimates	or,	if	required	
by	regulators,	based	upon	information	at	the	time	of	their	
examinations	or	upon	future	regulatory	guidance.	Such	
adjustments	to	original	estimates,	as	necessary,	are	made	
in	the	period	in	which	these	factors	and	other	relevant	
considerations	indicate	that	loss	levels	vary	from	previous	
estimates.

Management's	estimate	of	expected	credit	losses	in	the	
loan	and	lease	portfolio	is	recorded	in	the	ALLL	and	the	

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NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

reserve	for	unfunded	lending	commitments,	collectively	
the	ACL.	The	ACL	is	maintained	at	a	level	that	
management	determines	is	sufficient	to	absorb	current	
expected	credit	losses	in	the	loan	and	lease	portfolio	and	
unfunded	lending	commitments.	Management	uses	
analytical	models	to	estimate	expected	credit	losses	in	the	
loan	and	lease	portfolio	and	unfunded	lending	
commitments	as	of	the	balance	sheet	date.	The	models	
are	carefully	reviewed	to	identify	trends	that	may	not	be	
captured	in	the	modeled	loss	estimates.	Management	
uses	qualitative	adjustments	for	those	items	not	reflected	
in	the	modeled	loss	information	such	as	recent	changes	
from	the	macroeconomic	forecasts	utilized	in	model	
calculations,	results	of	additional	stressed	modeling	
scenarios,	observed	and/or	expected	changes	affecting	
borrowers	in	specific	industries	or	geographic	areas,	
exposure	to	large	lending	relationships	and	expected	
recoveries	of	prior	charge	offs.	Qualitative	adjustments	
are	also	used	to	accommodate	for	the	imprecision	of	
certain	assumptions	and	uncertainties	inherent	in	the	
model	calculations	as	well	as	to	align	certain	differences	in	
models	used	by	acquired	loan	portfolios	to	the	
methodologies	described	herein.	Loans	accounted	for	at	
elected	fair	value	are	excluded	from	CECL	measurements.	

The	ALLL	is	increased	by	the	provision	for	loan	and	lease	
losses	and	is	decreased	by	loan	charge-offs.	The	ALLL	is	
determined	in	accordance	with	ASC	326-20	"Financial	
Instruments	-	Credit	Losses".	ASC	326-20	was	adopted	on	
January	1,	2020	and	for	periods	prior	to	that	was	
determined	in	accordance	with	ASC	450-20-50	
"Contingencies	-	Accruals	for	Loss	Contingencies"	and	was	
composed	of	reserves	for	commercial	loans	evaluated	
based	on	pools	of	credit-graded	loans	and	reserves	for	
pools	of	smaller-balance	homogeneous	consumer	and	
commercial	loans.	The	reserve	factors	applied	to	these	
pools	were	an	estimate	of	probably	incurred	losses	based	
on	management's	evaluation	of	historical	net	losses	from	
loans	with	similar	characteristics.	Additionally,	the	ALLL	
included	specific	reserves	established	in	accordance	with	
ASC	310-10-35	for	loans	determined	by	management	to	
be	individually	impaired	as	well	as	reserves	associated	
with	purchased	credit	impaired	loans.	Management	used	
analytical	models	to	estimate	probable	incurred	losses	in	
the	loan	portfolio	as	of	the	balance	sheet	date.	The	
models,	which	were	primarily	driven	by	historical	losses,	
were	carefully	reviewed	to	identify	trends	that	may	not	
have	been	captured	in	the	historical	loss	factors	used	in	
the	models.	Management	used	qualitative	adjustments	
for	those	items	not	yet	captured	in	the	models	like	then-
current	events,	recent	trends	in	the	portfolio,	current	
underwriting	guidelines,	and	local	and	macroeconomic	
trends,	among	other	things.

Subsequent	to	December	31,	2019,	credit	loss	estimation	
is	based	on	the	amortized	cost	of	loans,	which	includes	
the	following:

1. Unpaid	principal	balance	for	originated	assets	or	

acquisition	price	for	purchased	assets

2. Accrued	interest	(see	elections	discussed	previously)

3. Accretion	or	amortization	of	premium,	discount,	and	

net	deferred	fees	or	costs

4. Collection	of	cash

5. Charge-offs

Premiums,	discounts	and	net	deferred	origination	costs/
fees	affect	the	calculated	amount	of	expected	credit	
losses	but	they	are	not	considered	when	determining	the	
amount	of	expected	credit	losses	that	are	recorded.

Under	CECL,	a	loan	must	be	pooled	when	it	shares	similar	
risk	characteristics	with	other	loans.	Loans	that	do	not	
share	similar	risk	characteristics	are	evaluated	individually.	
Expected	credit	loss	is	estimated	for	the	remaining	life	of	
loan(s),	which	is	limited	to	the	remaining	contractual	
term(s),	adjusted	for	prepayment	estimates,	which	are	
included	as	separate	inputs	into	modeled	loss	estimates.	
Renewals	and	extensions	are	not	anticipated	unless	they	
are	included	in	existing	loan	documentation	and	are	not	
unconditionally	cancellable	by	the	lender.	However,	losses	
are	estimated	over	the	estimated	remaining	life	of	
reasonably	expected	TDRs	which	can	extend	beyond	the	
current	remaining	contractual	term.

Management	has	developed	multiple	current	expected	
credit	losses	models	which	segment	the	loan	and	lease	
portfolio	by	borrower	type	and	loan	or	lease	type	to	
estimate	expected	lifetime	expected	credit	losses	for	loans	
and	leases	that	share	similar	risk	characteristics.	Estimates	
of	expected	credit	losses	incorporate	consideration	of	
available	information	that	is	relevant	to	assessing	the	
collectability	of	future	cash	flows.	This	includes	internal	
and	external	information	relating	to	past	events,	current	
conditions	and	reasonable	and	supportable	forecasts	of	
future	conditions.		FHN	utilizes	internal	and	external	
historical	loss	information,	as	applicable,	for	all	available	
historical	periods	as	the	initial	point	for	estimating	
expected	credit	losses.	Given	the	duration	of	historical	
information	available,	FHN	considers	its	internal	loss	
history	to	fully	incorporate	the	effects	of	prior	credit	
cycles.	The	historical	loss	information	may	be	adjusted	in	
situations	where	current	loan	characteristics	(e.g.,	
underwriting	criteria)	differ	from	those	in	existence	at	the	
time	the	historical	losses	occurred.	Historical	loss	
information	is	also	adjusted	for	differences	in	economic	
conditions,	macroeconomic	forecasts	and	other	factors	
management	considers	relevant	over	a	period	extending	
beyond	the	measurement	date	which	is	considered	
reasonable	and	supportable.	

FHN	generally	measures	expected	credit	losses	using	
undiscounted	cash	flow	methodologies.	Credit	
enhancements	(e.g.,	guarantors)	that	are	not	freestanding	
are	considered	in	the	estimation	of	uncollectible	cash	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

flows.	Estimation	of	expected	credit	losses	for	loan	
agreements	involving	collateral	maintenance	provisions	
include	consideration	of	the	value	of	the	collateral	and	
replenishment	requirements,	with	the	maximum	loss	
limited	to	the	difference	between	the	amortized	cost	of	
the	loan	and	the	fair	value	of	the	collateral.	Expected	
credit	losses	for	loans	for	which	foreclosure	is	probable	
are	measured	at	the	fair	value	of	collateral,	less	estimated	
costs	to	sell	when	disposition	through	sale	is	anticipated.	
Additionally,	for	borrowers	experiencing	financial	difficulty	
certain	loans	are	valued	at	the	fair	value	of	collateral	
when	repayment	is	expected	to	be	provided	substantially	
through	the	operation	of	the	collateral.		The	fair	value	of	
the	collateral	is	reduced	for	estimated	costs	to	sell	when	
repayment	is	expected	through	sale	of	the	collateral.	
Expected	credit	losses	for	TDRs	are	measured	in	
accordance	with	ASC	310-40,	which	generally	requires	a	
discounted	cash	flow	methodology,	whereby	the	loans	are	
measured	based	on	the	present	value	of	expected	future	
payments	discounted	at	the	loan’s	original	effective	
interest	rate.

Expected	recoveries	of	previously	charged-off	amounts	
are	also	included	as	a	qualitative	adjustment	in	the	
estimation	of	expected	credit	losses,	which	reduces	the	
amount	of	the	allowance	recognized.	Estimates	of	
recoveries	on	previously	charged-off	assets	included	in	the	
allowance	for	loan	losses	do	not	exceed	the	aggregate	of	
amounts	previously	written	off	and	expected	to	be	written	
off	for	an	individual	loan	or	pool.

Since	CECL	requires	the	estimation	of	credit	losses	for	the	
entire	expected	life	of	loans,	loss	estimates	are	highly	
sensitive	to	changes	in	macroeconomic	forecasts,	
especially	when	those	forecasts	change	dramatically	in	
short	time	periods.	Additionally,	under	CECL	credit	loss	
estimates	are	more	likely	to	increase	rapidly	in	periods	of	
loan	growth.

Expected	credit	losses	for	unfunded	commitments	are	
estimated	for	periods	where	the	commitment	is	not	
unconditionally	cancellable	by	FHN.	The	measurement	of	
expected	credit	losses	for	unfunded	commitments	mirrors	
that	of	loans	with	the	additional	estimate	of	future	draw	
rates	(timing	and	amount).The	liability	for	credit	losses	
inherent	in	lending-related	commitments,	such	as	letters	
of	credit	and	unfunded	loan	commitments,	is	included	in	
Other	liabilities	on	the	Consolidated	Balance	Sheets	and	
established	through	a	charge	to	the	provision	for	credit	
losses.

Premises	and	Equipment

Premises	and	equipment	are	carried	at	cost	less	
accumulated	depreciation	and	amortization	and	include	
additions	that	materially	extend	the	useful	lives	of	existing	
premises	and	equipment.	All	other	maintenance	and	
repair	expenditures	are	expensed	as	incurred.	Premises	
and	equipment	held	for	sale	are	generally	valued	at	
appraised	values	which	reference	recent	disposition	

values	for	similar	property	types	but	also	consider	
marketability	discounts	for	vacant	properties.	The	
valuations	of	premises	and	equipment	held	for	sale	are	
reduced	by	estimated	costs	to	sell.	Impairments,	and	any	
subsequent	recoveries,	are	recorded	in	noninterest	
expense.	Gains	and	losses	on	dispositions	are	reflected	in	
noninterest	income	and	expense,	respectively.

Depreciation	and	amortization	are	computed	on	the	
straight-line	method	over	the	estimated	useful	lives	of	the	
assets	and	are	recorded	as	noninterest	expense.	
Leasehold	improvements	are	amortized	over	the	lesser	of	
the	lease	periods	or	the	estimated	useful	lives	using	the	
straight-line	method.	Useful	lives	utilized	in	determining	
depreciation	for	furniture,	fixtures	and	equipment	and	for	
buildings	are	three	years	to	fifteen	years	and	seven	years	
to	forty-five	years,	respectively.	

Other	Real	Estate	Owned

Real	estate	acquired	by	foreclosure	or	other	real	estate-
owned	consists	of	properties	that	have	been	acquired	in	
satisfaction	of	debt.	These	properties	are	carried	at	the	
lower	of	the	outstanding	loan	amount	or	estimated	fair	
value	less	estimated	costs	to	sell	the	real	estate.	At	the	
time	acquired,	and	in	conjunction	with	the	transfer	from	
loans	to	OREO,	there	is	a	charge-off	against	the	ALLL	if	the	
estimated	fair	value	less	costs	to	sell	is	less	than	the	loan’s	
cost	basis.	Subsequent	declines	in	fair	value	and	gains	or	
losses	on	dispositions,	if	any,	are	charged	to	other	
expense	on	the	Consolidated	Statements	of	Income.	

Required	developmental	costs	associated	with	acquired	
property	under	construction	are	capitalized	and	included	
in	determining	the	estimated	net	realizable	value	of	the	
property,	which	is	reviewed	periodically,	and	any	write-
downs	are	charged	against	current	earnings.

Goodwill	and	Other	Intangible	Assets

Goodwill	represents	the	excess	of	cost	over	net	assets	of	
acquired	businesses	less	identifiable	intangible	assets.	On	
an	annual	basis,	or	more	frequently	if	necessary,	FHN	
assesses	goodwill	for	impairment.	Other	intangible	assets	
primarily	represent	client	lists	and	relationships,	acquired	
contracts,	covenants	not	to	compete	and	premium	on	
purchased	deposits,	which	are	amortized	over	their	
estimated	useful	lives.	Intangible	assets	related	to	
acquired	deposit	bases	are	primarily	amortized	over	10	
years	using	an	accelerated	method.	Management	
evaluates	whether	events	or	circumstances	have	occurred	
that	indicate	the	remaining	useful	life	or	carrying	value	of	
amortizing	intangibles	should	be	revised.	Other	
intangibles	also	include	smaller	amounts	of	non-
amortizing	intangibles	for	title	plant	and	state	banking	
licenses.

Servicing	Rights

FHN	recognizes	the	rights	to	service	mortgage	and	other	
loans	as	separate	assets,	which	are	recorded	in	other	
assets	in	the	Consolidated	Balance	Sheets,	when	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

purchased	or	when	servicing	is	contractually	separated	
from	the	underlying	loans	by	sale	with	servicing	rights	
retained.	For	loan	sales	with	servicing	retained,	a	servicing	
right,	generally	an	asset,	is	recorded	at	fair	value	at	the	
time	of	sale	for	the	right	to	service	the	loans	sold.	All	
servicing	rights	are	identified	by	class	and	amortized	over	
the	remaining	life	of	the	loan	with	periodic	reviews	for	
impairment.

Transfers	of	Financial	Assets

Transfers	of	financial	assets,	or	portions	thereof	which	
meet	the	definition	of	a	participating	interest,	are	
accounted	for	as	sales	when	control	over	the	assets	has	
been	surrendered.	Control	over	transferred	assets	is	
deemed	to	be	surrendered	when	1)	the	assets	have	been	
legally	isolated	from	FHN,	2)	the	transferee	has	the	right	
to	pledge	or	exchange	the	assets	with	no	conditions	that	
constrain	the	transferee	and	provide	more	than	a	trivial	
benefit	to	FHN,	and	3)	FHN	does	not	maintain	effective	
control	over	the	transferred	assets.	If	the	transfer	does	
not	satisfy	all	three	criteria,	the	transaction	is	recorded	as	
a	secured	borrowing.	If	the	transfer	is	accounted	for	as	a	
sale,	the	transferred	assets	are	derecognized	from	FHN’s	
balance	sheet	and	a	gain	or	loss	on	sale	is	recognized.	If	
the	transfer	is	accounted	for	as	a	secured	borrowing,	the	
transferred	assets	remain	on	FHN’s	balance	sheet	and	the	
proceeds	from	the	transaction	are	recognized	as	a	liability.

Derivative	Financial	Instruments

FHN	accounts	for	derivative	financial	instruments	in	
accordance	with	ASC	815	which	requires	recognition	of	all	
derivative	instruments	on	the	balance	sheet	as	either	an	
asset	or	liability	measured	at	fair	value	through	
adjustments	to	either	accumulated	other	comprehensive	
income	within	shareholders’	equity	or	current	earnings.	
Fair	value	is	defined	as	the	price	that	would	be	received	to	
sell	a	derivative	asset	or	paid	to	transfer	a	derivative	
liability	in	an	orderly	transaction	between	market	
participants	on	the	transaction	date.	Fair	value	is	
determined	using	available	market	information	and	
appropriate	valuation	methodologies.	FHN	has	elected	to	
present	its	derivative	assets	and	liabilities	gross	on	the	
Consolidated	Balance	Sheets.	Amounts	of	collateral	
posted	or	received	have	not	been	netted	with	the	related	
derivatives	unless	the	collateral	amounts	are	considered	
legal	settlements	of	the	related	derivative	positions.	See	
Note	22	-	Derivatives	for	discussion	on	netting	of	
derivatives.

FHN	prepares	written	hedge	documentation,	identifying	
the	risk	management	objective	and	designating	the	
derivative	instrument	as	a	fair	value	hedge	or	cash	flow	
hedge	as	applicable,	or	as	a	free-standing	derivative	
instrument	entered	into	as	an	economic	hedge	or	to	meet	
clients’	needs.	All	transactions	designated	as	ASC	815	
hedges	must	be	assessed	at	inception	and	on	an	ongoing	
basis	as	to	the	effectiveness	of	the	derivative	instrument	
in	offsetting	changes	in	fair	value	or	cash	flows	of	the	

hedged	item.	For	a	fair	value	hedge,	changes	in	the	fair	
value	of	the	derivative	instrument	and	changes	in	the	fair	
value	of	the	hedged	asset	or	liability	attributable	to	the	
hedged	risk	are	recognized	currently	in	earnings.	For	a	
cash	flow	hedge,	changes	in	the	fair	value	of	the	derivative	
instrument	are	recorded	in	accumulated	other	
comprehensive	income	and	subsequently	reclassified	to	
earnings	as	the	hedged	transaction	impacts	net	income.	
For	fair	value	hedges,	the	entire	change	in	the	fair	value	of	
the	hedging	instrument	included	in	the	assessment	of	
effectiveness	is	recorded	to	the	same	financial	statement	
line	item	(e.g.,	interest	expense)	used	to	present	the	
earnings	effect	of	the	hedged	item.	For	cash	flow	hedges,	
the	entire	fair	value	change	of	the	hedging	instrument	
that	is	included	in	the	assessment	of	hedge	effectiveness	
is	initially	recorded	in	other	comprehensive	income	and	
later	recycled	into	earnings	as	the	hedged	transaction(s)	
affect	net	income	with	the	income	statement	effects	
recorded	in	the	same	financial	statement	line	item	used	to	
present	the	earnings	effect	of	the	hedged	item	(e.g.,	
interest	income).	For	free-standing	derivative	instruments,	
changes	in	fair	values	are	recognized	currently	in	earnings.	
See	Note	22	-	Derivatives	for	additional	information.

Cash	flows	from	derivative	contracts	are	reported	as	
operating	activities	on	the	Consolidated	Statements	of	
Cash	Flows.

Leases

At	inception,	all	arrangements	are	evaluated	to	determine	
if	they	contain	a	lease,	which	is	defined	as	a	contract,	or	
part	of	a	contract,	that	conveys	the	right	to	control	the	
use	of	identified	property,	plant,	or	equipment	for	a	
period	of	time	in	exchange	for	consideration.	Control	is	
deemed	to	exist	when	a	lessor	has	granted	and	a	lessee	
has	received	both	the	right	to	obtain	substantially	all	of	
the	economic	benefits	from	use	of	the	identified	asset	and	
the	right	to	direct	the	use	of	the	identified	asset	
throughout	the	period	of	use.

Lessee

As	a	lessee,	FHN	recognizes	lease	(right-of-use)	assets	and	
lease	liabilities	for	all	leasing	arrangements	with	lease	
terms	that	are	greater	than	one	year.	The	lease	asset	and	
lease	liability	are	recognized	at	the	present	value	of	
estimated	future	lease	payments,	including	estimated	
renewal	periods,	with	the	discount	rate	reflecting	a	fully-
collateralized	rate	matching	the	estimated	lease	term.	
Renewal	options	are	included	in	the	estimated	lease	term	
if	they	are	considered	reasonably	certain	of	exercise.	
Periods	covered	by	termination	options	are	included	in	
the	lease	term	if	it	is	reasonably	certain	they	will	not	be	
exercised.	Additionally,	prepaid	or	accrued	lease	
payments,	lease	incentives	and	initial	direct	costs	related	
to	lease	arrangements	are	recognized	within	the	right-of-
use	asset.	Each	lease	is	classified	as	a	financing	or	
operating	lease	which	depends	on	the	relationship	of	the	
lessee’s	rights	to	the	economic	value	of	the	leased	asset.	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

For	finance	leases,	interest	on	the	lease	liability	is	
recognized	separately	from	amortization	of	the	right-of-
use	asset	in	earnings,	resulting	in	higher	expense	in	the	
earlier	portion	of	the	lease	term.	For	operating	leases,	a	
single	lease	cost	is	calculated	so	that	the	cost	of	the	lease	
is	allocated	over	the	lease	term	on	a	generally	straight-line	
basis.	Substantially	all	of	FHN’s	lessee	arrangements	are	
classified	as	operating	leases.	For	leases	with	a	term	of	12	
months	or	less,	FHN	does	not	to	recognize	lease	assets	
and	lease	liabilities	and	expense	is	generally	recognized	on	
a	straight-line	basis	over	the	lease	term.	

Lease	assumptions	and	classification	are	reassessed	upon	
the	occurrence	of	events	that	result	in	changes	to	the	
estimated	lease	term	or	consideration.	Modifications	to	
lease	contracts	are	evaluated	to	determine	1)	if	a	right	to	
use	an	additional	asset	has	been	obtained,	2)	if	only	the	
lease	term	and/or	consideration	have	been	revised	or	3)	if	
a	full	or	partial	termination	has	occurred.	If	an	additional	
right-of	use-asset	has	been	obtained,	the	modification	is	
treated	as	a	separate	contract	and	its	classification	is	
evaluated	as	a	new	lease	arrangement.	If	only	the	lease	
term	or	consideration	are	changed,	the	lease	liability	is	
revalued	with	an	offset	to	the	lease	asset	and	the	lease	
classification	is	re-assessed.	If	a	modification	results	in	a	
full	or	partial	termination	of	the	lease,	the	lease	liability	is	
revalued	through	earnings	along	with	a	proportionate	
reduction	in	the	value	of	the	related	lease	asset	and	
subsequent	expense	recognition	is	similar	to	a	new	lease	
arrangement.

Lease	assets	are	evaluated	for	impairment	when	triggering	
events	occur,	such	as	a	change	in	management	intent	
regarding	the	continued	occupation	of	the	leased	space.	If	
a	lease	asset	is	impaired,	it	is	written	down	to	the	present	
value	of	estimated	future	cash	flows	and	the	prospective	
expense	recognition	for	that	lease	follows	the	accelerated	
expense	recognition	methodology	applicable	to	finance	
leases,	even	if	it	remains	classified	as	an	operating	lease.

Sublease	arrangements	are	accounted	for	consistent	with	
the	lessor	accounting	described	below.	Sublease	
arrangements	are	evaluated	to	determine	if	changes	to	
estimates	for	the	primary	lease	are	warranted	or	if	the	
sublease	terms	reflect	impairment	of	the	related	lease	
asset.

Lease	assets	are	recognized	in	Other	assets	and	lease	
liabilities	are	recognized	in	Other	liabilities	in	the	
Consolidated	Balance	Sheets.	Since	substantially	all	of	its	
leasing	arrangements	relate	to	real	estate,	FHN	records	
lease	expense,	and	any	related	sublease	income,	within	
Occupancy	expense	in	the	Consolidated	Statements	of	
Income.	

Lessor

As	a	lessor,	FHN	also	evaluates	its	lease	arrangements	to	
determine	whether	a	finance	lease	or	an	operating	lease	
exists	and	utilizes	the	rate	implicit	in	the	lease	

arrangement	as	the	discount	rate	to	calculate	the	present	
value	of	future	cash	flows.	Depending	upon	the	terms	of	
the	individual	agreements,	finance	leases	represent	either	
sales-type	or	direct	financing	leases,	both	of	which	require	
de-recognition	of	the	asset	being	leased	with	offsetting	
recognition	of	a	lease	receivable	that	is	evaluated	for	
impairment	similar	to	loans.	Other	than	equipment	lease	
entered	into	as	part	of	commercial	lease	financing	
arrangements,	all	of	FHN's	lessor	arrangements	are	
considered	operating	leases.	

Lease	income	for	operating	leases	is	recognized	over	the	
life	of	the	lease,	generally	on	a	straight	line	basis.	Lease	
incentives	and	initial	direct	costs	are	capitalized	and	
amortized	over	the	estimated	life	of	the	lease.	Lease	
income	is	not	significant	for	any	reporting	periods	and	is	
classified	as	a	reduction	of	net	occupancy	expense	in	the	
Consolidated	Statements	of	Income.

Investment	Tax	Credit

FHN	has	elected	to	utilize	the	deferral	method	for	
acquired	investments	that	generate	investment	tax	
credits.	This	includes	both	solar	and	historic	tax	credit	
investments.	Under	this	approach	the	investment	tax	
credits	are	recorded	as	an	offset	to	the	related	investment	
on	the	balance	sheet.	Credit	amounts	are	recognized	in	
earnings	over	the	life	of	the	investment	within	the	same	
income	or	expense	accounts	as	used	for	the	investment.

Advertising	and	Public	Relations

Advertising	and	public	relations	costs	are	generally	
expensed	as	incurred.

Income	Taxes

FHN	accounts	for	income	taxes	using	the	asset	and	liability	
method	pursuant	to	ASC	740,	“Income	Taxes,”	which	
requires	the	recognition	of	deferred	tax	assets	and	
liabilities	for	the	expected	future	tax	consequences	of	
events	that	have	been	included	in	the	financial	
statements.	Under	this	method,	FHN’s	deferred	tax	assets	
and	liabilities	are	determined	based	on	differences	
between	financial	statement	carrying	amounts	and	the	
corresponding	tax	basis	of	certain	assets	and	liabilities	
using	enacted	tax	rates	in	effect	for	the	year	in	which	the	
differences	are	expected	to	reverse.	The	effect	of	a	
change	in	tax	rates	on	DTAs	and	DTLs	is	recognized	in	
income	in	the	period	that	includes	the	enactment	date.	

Additionally,	DTAs	are	subject	to	a	“more	likely	than	not”	
test	to	determine	whether	the	full	amount	of	the	DTAs	
should	be	recognized	in	the	financial	statements.	FHN	
evaluates	the	likelihood	of	realization	of	the	DTA	based	on	
both	positive	and	negative	evidence	available	at	the	time,	
including	(as	appropriate)	scheduled	reversals	of	DTLs,	
projected	future	taxable	income,	tax	planning	strategies,	
and	recent	financial	performance.	If	the	“more	likely	than	
not”	test	is	not	met,	a	valuation	allowance	must	be	
established	against	the	DTA.	In	the	event	FHN	determines	
that	DTAs	are	realizable	in	the	future	in	excess	of	their	net	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

recorded	amount,	FHN	would	make	an	adjustment	to	the	
valuation	allowance,	which	would	reduce	income	tax	
expense.

FHN	records	uncertain	tax	positions	in	accordance	with	
ASC	740	on	the	basis	of	a	two-step	process	in	which	(1)	it	
is	determined	whether	it	is	more	likely	than	not	that	the	
tax	positions	will	be	sustained	on	the	basis	of	the	technical	
merits	of	the	position	and	(2)	for	those	tax	positions	that	
meet	the	more-likely-than-not	recognition	threshold,	the	
largest	amount	of	tax	benefit	that	is	more	than	50	percent	
likely	to	be	realized	upon	ultimate	settlement	with	the	
related	tax	authority	is	recognized.	FHN's	ASC	740	policy	is	
to	recognize	interest	and	penalties	related	to	
unrecognized	tax	benefits	as	a	component	of	income	tax	
expense.	Accrued	interest	and	penalties	are	included	
within	the	related	tax	asset/liability	line	in	the	
Consolidated	Balance	Sheet.

FHN	and	its	eligible	subsidiaries	are	included	in	a	
consolidated	federal	income	tax	return.	FHN	files	separate	
returns	for	subsidiaries	that	are	not	eligible	to	be	included	
in	a	consolidated	federal	income	tax	return.	Based	on	the	
laws	of	the	applicable	state	where	it	conducts	business	
operations,	FHN	either	files	consolidated,	combined,	or	
separate	returns.	

Earnings	per	Share

Earnings	per	share	is	computed	by	dividing	net	income	or	
loss	available	to	common	shareholders	by	the	weighted	
average	number	of	common	shares	outstanding	for	each	
period.	Diluted	earnings	per	share	in	net	income	periods	is	
computed	by	dividing	net	income	available	to	common	
shareholders	by	the	weighted	average	number	of	
common	shares	outstanding	adjusted	to	include	the	
number	of	additional	common	shares	that	would	have	
been	outstanding	if	the	potential	dilutive	common	shares	
resulting	from	performance	shares	and	units,	restricted	
shares	and	units,	and	options	granted	under	FHN’s	equity	
compensation	plans	and	deferred	compensation	
arrangements	had	been	issued.	FHN	utilizes	the	treasury	
stock	method	in	this	calculation.	Diluted	earnings	per	
share	does	not	reflect	an	adjustment	for	potentially	
dilutive	shares	in	periods	in	which	a	net	loss	available	to	
common	shareholders	exists.

Equity	Compensation

FHN	accounts	for	its	employee	stock-based	compensation	
plans	using	the	grant	date	fair	value	of	an	award	to	
determine	the	expense	to	be	recognized	over	the	life	of	
the	award.	Stock	options	are	valued	using	an	option-
pricing	model,	such	as	Black-Scholes.	Restricted	and	
performance	shares	and	share	units	are	valued	at	the	
stock	price	on	the	grant	date.	For	awards	with	service	
vesting	criteria,	expense	is	recognized	using	the	straight-
line	method	over	the	requisite	service	period	(generally	
the	vesting	period).	Forfeitures	are	recognized	when	they	
occur.	For	awards	vesting	based	on	a	performance	
measure,	anticipated	performance	is	projected	to	

determine	the	number	of	awards	expected	to	vest,	and	
the	corresponding	aggregate	expense	is	adjusted	to	reflect	
the	elapsed	portion	of	the	performance	period.	If	a	
performance	period	extends	beyond	the	required	service	
term,	total	expense	is	adjusted	for	changes	in	estimated	
achievement	through	the	end	of	the	performance	period.	
Some	performance	awards	include	a	total	shareholder	
return	modifier	(“TSR	Modifier”)	that	operates	after	
determination	of	the	performance	criteria,	affecting	only	
the	quantity	of	awards	issued	if	the	minimum	
performance	threshold	is	attained.	The	effect	of	the	TSR	
Modifier	is	included	in	the	grant	date	fair	value	of	the	
related	performance	awards	using	a	Monte	Carlo	
valuation	technique.	The	fair	value	of	equity	awards	with	
cash	payout	requirements,	as	well	as	awards	for	which	fair	
value	cannot	be	estimated	at	grant	date,	is	remeasured	
each	reporting	period	through	vesting	date.	Performance	
awards	with	pre-grant	date	achievement	criteria	are	
expensed	over	the	period	from	the	start	of	the	
performance	period	through	the	end	of	the	service	vesting	
term.	Awards	are	amortized	using	the	nonsubstantive	
vesting	methodology	which	requires	that	expense	
associated	with	awards	having	only	service	vesting	criteria	
that	continue	vesting	after	retirement	be	recognized	over	
a	period	ending	no	later	than	an	employee’s	retirement	
eligibility	date.

Phantom	stock	awards	are	accounted	for	as	liability	
awards	and	are	remeasured	at	each	reporting	period	
based	on	changes	in	their	fair	value,	which	is	based	on	
changes	in	common	share	prices,	until	the	date	of	cash	
settlement.	Compensation	cost	for	each	reporting	period	
until	settlement	is	based	on	the	change	(or	a	portion	of	
the	change,	depending	on	the	percentage	of	the	requisite	
service	that	has	been	rendered	at	the	reporting	date)	in	
the	fair	value	of	the	phantom	stock	award	for	each	
reporting	period.

Repurchase	and	Foreclosure	Provision

The	repurchase	and	foreclosure	provision	is	the	charge	to	
earnings	necessary	to	maintain	the	liability	at	a	level	that	
reflects	management’s	best	estimate	of	losses	associated	
with	the	repurchase	of	loans	previously	transferred	in	
whole	loans	sales	or	securitizations,	or	make	whole	
requests	as	of	the	balance	sheet	date.	See	Note	17	-	
Contingencies	and	Other	Disclosures	for	discussion	related	
to	FHN’s	obligations	to	repurchase	such	loans.

Legal	Costs

Generally,	legal	costs	are	expensed	as	incurred.Costs	
related	to	equity	issuances	are	netted	against	capital	
surplus.	Costs	related	to	debt	issuances	are	included	in	
debt	issuance	costs	that	are	recorded	within	term	
borrowings.

Contingency	Accruals

Contingent	liabilities	arise	in	the	ordinary	course	of	
business,	including	those	related	to	lawsuits,	arbitration,	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

mediation,	and	other	forms	of	litigation.	FHN	establishes	
loss	contingency	liabilities	for	matters	when	loss	is	both	
probable	and	reasonably	estimable	in	accordance	with	
ASC	450-20-50	“Contingencies	-	Accruals	for	Loss	
Contingencies”.	If	loss	for	a	matter	is	probable	and	a	range	
of	possible	loss	outcomes	is	the	best	estimate	available,	
accounting	guidance	generally	requires	a	liability	to	be	
established	at	the	low	end	of	the	range.	Expected	
recoveries	from	insurance	and	indemnification	
arrangements	are	recognized	if	they	are	considered	
equally	as	probable	and	reasonably	estimable	as	the	
related	loss	contingency	up	to	the	recognized	amount	of	
the	estimated	loss.	Gain	contingencies	and	expected	
recoveries	from	insurance	and	indemnification	
arrangements	in	excess	of	the	associated	recorded	
estimated	losses	are	generally	recognized	when	received.	
Recognized	recoveries	are	recorded	as	offsets	to	the	
related	expense	in	the	Consolidated	Statements	of	
Income.	The	favorable	resolution	of	a	gain	contingency	
generally	results	in	the	recognition	of	other	income	in	the	
Consolidated	Statements	of	Income.	Contingencies	
assumed	in	business	combinations	are	evaluated	through	
the	end	of	the	one-year	post-closing	measurement	
period.		If	the	acquisition-date	fair	value	of	the	
contingency	can	be	determined	during	the	measurement	
period,	recognition	occurs	as	part	of	the	acquisition-date	
fair	value	of	the	acquired	business.	If	the	acquisition-date	
fair	value	of	the	contingency	cannot	be	determined,	but	
loss	is	considered	probable	as	of	the	acquisition	date	and	
can	be	reasonably	estimated	within	the	measurement	
period,	then	the	estimated	amount	is	recorded	within	
acquisition	accounting.	If	the	requirements	for	inclusion	of	
the	contingency	as	part	of	the	acquisition	are	not	met,	
subsequent	recognition	of	the	contingency	is	included	in	
earnings.

Business	Combinations

Assets	and	liabilities	acquired	in	business	combinations	
are	generally	recognized	at	their	fair	values	as	of	the	
acquisition	date,	with	the	related	transaction	costs	
expensed	in	the	period	incurred.	Specified	items	such	as	
net	investment	in	leases	as	lessor,	acquired	operating	
lease	assets	and	liabilities	as	lessee,	employee	benefit	
plans	and	income-tax	related	balances	are	recognized	in	
accordance	with	accounting	guidance	that	results	in	
measurements	that	may	differ	from	fair	value.		FHN	may	
record	provisional	amounts	at	the	time	of	acquisition	
based	on	available	information.	The	provisional	valuation	
estimates	may	be	adjusted	for	a	period	of	up	to	one	year	
(“measurement	period”)	from	the	date	of	acquisition	if	
new	information	is	obtained	about	facts	and	
circumstances	that	existed	as	of	the	acquisition	date	that,	
if	known,	would	have	affected	the	measurement	of	the	
amounts	recognized	as	of	that	date.	Business	
combinations	are	included	in	the	financial	statements	
from	the	respective	dates	of	acquisition.	Adjustments	
recorded	during	the	measurement	period	are	recognized	
in	the	current	reporting	period.

The	excess	of	purchase	price	over	the	valuation	of	
specifically	identified	assets	and	liabilities	is	recorded	as	
goodwill.		In	certain	circumstances	the	net	values	of	assets	
and	liabilities	acquired	may	exceed	the	purchase	price,	
which	is	recognized	within	non-interest	income	as	a	
purchase	accounting	gain.

2022	Merger	Agreement	with	Toronto-Dominion	Bank

On	February	27,	2022,	FHN	entered	into	an	Agreement	
and	Plan	of	Merger	(the	“TD	Merger	Agreement”)	with	
The	Toronto-Dominion	Bank,	a	Canadian	chartered	bank	
(“TD”),	TD	Bank	US	Holding	Company,	a	Delaware	
corporation	and	indirect,	wholly	owned	subsidiary	of	TD	
(“TD-US”),	and	Falcon	Holdings	Acquisition	Co.,	a	
Delaware	corporation	and	direct,	wholly	owned	subsidiary	
of	TD-US	(“Merger	Sub”).	Refer	to	Note	27	–	Subsequent	
Events,	beginning	on	page	212,	for	additional	information	
regarding	the	proposed	transaction.	Merger	and	
integration	expenses	related	to	the	Proposed	TD	Merger	
will	be	recorded	in	FHN’s	Corporate	segment.	No	such	
expenses	were	recognized	during	2021.

Accounting	Changes	With	Extended	Transition	Periods

In	March	2020,	the	FASB	issued	ASU	2020-04,	“Facilitation	
of	the	Effects	of	Reference	Rate	Reform	on	Financial	
Reporting”	which	provides	several	optional	expedients	
and	exceptions	to	ease	the	potential	burden	in	accounting	
for	(or	recognizing	the	effects	of)	reference	rate	reform	on	
financial	reporting.	The	provisions	of	ASU	2020-04	
primarily	affect	1)	contract	modifications	(e.g.,	loans,	
leases,	debt,	and	derivatives)	made	in	anticipation	that	a	
reference	rate	(e.g.,	LIBOR)	will	be	discontinued	and	2)	the	
application	of	hedge	accounting	for	existing	relationships	
affected	by	those	modifications.	The	provisions	of	ASU	
2020-04	are	effective	upon	release	and	apply	only	to	
contracts,	hedging	relationships,	and	other	transactions	
that	reference	LIBOR	or	another	reference	rate	expected	
to	be	discontinued	because	of	reference	rate	reform.	The	
expedients	and	exceptions	provided	by	ASU	2020-04	do	
not	apply	to	contract	modifications	made	and	hedging	
relationships	entered	into	or	evaluated	after	December	
31,	2022,	except	for	hedging	relationships	existing	as	of	
December	31,	2022,	that	an	entity	has	elected	certain	
optional	expedients	for	and	that	are	retained	through	the	
end	of	the	hedging	relationship.	FHN	has	identified	
contracts	affected	by	reference	rate	reform	and	
developed	modification	plans	for	those	contracts.	FHN	has	
elected	to	utilize	the	optional	expedients	and	exceptions	
provided	by	ASU	2020-04	for	certain	contract	
modifications	that	have	already	been	implemented.	FHN	
anticipates	that	it	will	continue	to	utilize	the	expedients	
and	exceptions	for	future	modifications	in	situations	
where	they	mitigate	potential	accounting	outcomes	that	
do	not	faithfully	represent	management’s	intent	or	risk	
management	activities,	consistent	with	the	purpose	of	the	
standard.

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NOTE	1—SIGNIFICANT	ACCOUNTING	POLICIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

The	FASB	has	voted	to	approve	an	extension	of	the	
transition	window	for	ASU	2020-04	until	December	31,	
2024,	consistent	with	key	USD	LIBOR	tenors	continuing	to	
be	published	through	June	30,	2023.

In	January	2021,	the	FASB	issued	ASU	2021-01,	"Scope"	to	
expand	the	scope	of	ASU	2020-04	to	apply	to	certain	
contract	modifications	that	were	implemented	in	October	
2020	by	derivative	clearinghouses	for	the	use	of	Secure	
Overnight	Funding	Rate	(SOFR)	in	discounting,	margining	
and	price	alignment	for	centrally	cleared	derivatives,	
including	derivatives	utilized	in	hedging	relationships.	ASU	
2021-01	also	applies	to	derivative	contracts	affected	by	
the	change	in	discounting	convention	regardless	of	
whether	they	are	centrally	cleared	(i.e.,	bi-lateral	
contracts	can	also	be	modified)	and	regardless	of	whether	
they	reference	LIBOR.	ASU	2021-01	was	effective	
immediately	upon	issuance	with	retroactive	application	
permitted.	FHN	elected	to	retroactively	apply	the	
provisions	of	ASU	2021-01	because	FHN's	centrally	cleared	
derivatives	were	affected	by	the	change	in	discounting	
convention	and	because	FHN	has	other	bi-lateral	
derivative	contracts	that	may	be	modified	to	conform	to	
the	use	of	SOFR	for	discounting.	Adoption	did	not	have	a	
significant	effect	on	FHN's	reported	financial	condition	or	
results	of	operations.

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NOTE	2—ACQUISITIONS	&	DIVESTITURES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 2—Acquisitions and Divestitures 

IBKC	Merger	of	Equals

On	July	1,	2020,	FHN	and	IBERIABANK	Corporation	closed	
their	merger-of-equals	transaction.	FHN	issued	
approximately	243	million	shares	of	FHN	common	stock,	
plus	three	new	series	of	preferred	stock	(Series	B,	Series	C,	
and	Series	D)	in	a	transaction	valued	at	$2.5	billion.	At	the	
time	of	closing,	IBKC	operated	319	offices	in	12	states,	
mostly	in	the	southern	U.S.	

The	merger-of-equals	transaction	was	accounted	for	as	a	
business	combination.	Accordingly,	the	assets	acquired	

Table	8.2.1

and	liabilities	assumed	are	generally	presented	at	their	fair	
values	as	of	the	merger	date.	The	determination	of	fair	
value	requires	management	to	make	estimates	about	
discount	rates,	future	expected	cash	flows,	market	
conditions	and	other	future	events	that	are	highly	
subjective	in	nature	and	subject	to	change.	

The	following	schedule	details	the	allocation	of	merger	
consideration	to	the	valuations	of	the	identifiable	tangible	
and	intangible	assets	acquired	and	liabilities	assumed	
from	IBKC	as	of	July	1,	2020.

MERGER	CONSIDERATION	ALLOCATIONS

IBERIABANK	Corporation

(Dollars	in	millions)

Assets:
Cash	and	due	from	banks
Interest-bearing	deposits	with	banks

Securities	available	for	sale	at	fair	value

Loans	held	for	sale

Loans	and	leases	(a)

Allowance	for	loan	and	lease	losses

Other	intangible	assets

Premises	and	equipment

OREO

Other	assets

Total	assets	acquired

Liabilities:
Deposits

Short-term	borrowings

Term	borrowings

Other	liabilities

Total	liabilities	assumed
Net	assets	acquired

$	

$	

$	

$	

$	

$	

$	

$	

395	
1,683	

3,544	

320	

25,921	

(284)	

240	

311	

9	

1,153	

33,292	

28,232	

209	

1,200	

618	

30,259	

3,033	

2,243	

28	

231	

2,502	

(531)	

Consideration	paid:
Consideration	for	outstanding	common	stock

Consideration	for	equity	awards

Consideration	for	preferred	stock

Total	consideration	paid

Purchase	accounting	gain

(a)		 Includes	$1.3	billion	of	initial	net	investments	in	sales-type	and	direct	financing	leases.

In	relation	to	the	merger-of-equals,	FHN	recorded	a	
$531	million	purchase	accounting	gain,	representing	the	
shortfall	of	the	purchase	price	under	the	acquisition	
accounting	value	of	net	assets	acquired,	net	of	deferred	
taxes.	The	purchase	accounting	gain	is	not	taxable.	The	
valuation	of	the	IBKC	merger-of-equals	transaction	was	
final	as	of	June	30,	2021.	

On	July	17,	2020,	First	Horizon	Bank	completed	its	
purchase	of	30	branches	from	Truist	Bank.	As	of	December	
31,	2020,	the	valuation	of	the	acquired	assets	and	
liabilities	assumed	from	the	Truist	branches	acquisition	
was	final.	In	relation	to	the	acquisition,	FHN	recorded	
$78	million	in	goodwill,	representing	the	excess	of	
acquisition	consideration	over	the	estimated	fair	value	of	
net	assets	acquired.	All	goodwill	has	been	attributed	to	
FHN's	Regional	Banking	segment	(refer	to	Note	7	-	

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NOTE	2—ACQUISITIONS	&	DIVESTITURES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Goodwill	and	Other	Intangible	Assets	for	additional	
information).	This	goodwill	was	the	result	of	expected	
synergies,	operational	efficiencies	and	other	factors.

Total	merger	and	integration	expense	recognized	for	the	
years	ended	December	31,	2021	and	2020	are	presented	
in	the	following	table:

Expenses	related	to	FHN's	merger	and	integration	
activities	are	recorded	in	FHN's	Corporate	segment.

Table	8.2.2

(Dollars	in	millions)

Personnel	expense	(a)

Impairment	of	long-lived	assets

Legal	and	professional	fees		(b)

Contract	employment	and	outsourcing

Advertising	and	public	relations

Contribution	expense	(c)

Other	expense	(d)

Total

MERGER	&	INTEGRATION	EXPENSE

2021

2020

$	

$	

56	 $	

34	

21	

12	

10	

—	

54	

187	 $	

66	

6	

39	

1	

—	

20	

23	

155	

(a)	 Primarily	comprised	of	fees	for	severance	and	retention.
(b)		 Primarily	comprised	of	fees	for	legal,	accounting,	and	merger	consultants.
(c)	 Comprised	of	contribution	expense	related	to	the	establishment	of	the	Louisiana	First	Horizon	Foundation.
(d)		 Consists	of	operation	services,	communications	and	delivery,	equipment	expense,	supplies,	travel	and	entertainment,	computer	software,	occupancy	

expense	(including	costs	associated	with	lease	exits)	and	costs	of	shareholder	matters.	

In	addition	to	the	transactions	mentioned	above,	FHN	
acquires	or	divests	assets	from	time	to	time	in	
transactions	that	are	considered	business	combinations	or	
divestitures	but	are	not	material	to	FHN	individually	or	in	
the	aggregate.

2022	Merger	Agreement	with	Toronto-Dominion	Bank

On	February	27,	2022,	FHN	entered	into	the	TD	Merger	
Agreement	with	TD,	TD-US,	and	Merger	Sub.	Refer	to	Note	

27—Subsequent	Events	for	additional	information	
regarding	the	proposed	transaction.	Merger	and	
integration	expenses	related	to	the	Proposed	TD	Merger	
will	be	recorded	in	FHN’s	Corporate	segment.	No	such	
expenses	were	recognized	during	2021.

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NOTE	3—INVESTMENT	SECURITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 3—Investment Securities

The	following	tables	summarize	FHN’s	investment	securities	as	of	December	31,	2021	and	2020:

Table	8.3.1a

INVESTMENT	SECURITIES	AT	YE	2021

(Dollars	in	millions)

Securities	available	for	sale:

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities
Total	securities	available	for	sale	(a)

Securities	held	to	maturity:

Government	agency	issued	MBS

Government	agency	issued	CMO

Total	securities	held	to	maturity

December	31,	2021

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Amortized
Cost

Fair
Value

$	

5,062	 $	

42	 $	

(49)	 $	

2,296	

861	

535	

8	

4	

11	

(47)	

(15)	

(1)	

8,754	 $	

65	 $	

(112)	 $	

509	 $	

203	

712	 $	

—	 $	

—	

—	 $	

(5)	 $	

(2)	

(7)	 $	

$	

$	

$	

5,055	

2,257	

850	

545	

8,707	

504	

201	

705	

(a) Includes	$6.5	billion	of	securities	pledged	to	secure	public	deposits,	securities	sold	under	agreements	to	repurchase,	and	for	other	purposes.

Table	8.3.1b

INVESTMENT	SECURITIES	AT	YE	2020

(Dollars	in	millions)

Securities	available	for	sale:

U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

Corporate	and	other	debt

States	and	municipalities

AFS	securities	recorded	at	fair	value	through	earnings:

SBA	interest-only	strips	(a)

Total	securities	available	for	sale	(b)

Amortized
Cost

December	31,	2020

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Fair
Value

$	

613	 $	

—	 $	

—	 $	

3,722	

2,380	

672	

40	

445	

92	

29	

12	

1	

15	

$	

7,872	 $	

149	 $	

(2)	

(3)	

—	

(1)	

—	

(6)	

$	

—	 $	

—	 $	

613	

3,812	

2,406	

684	

40	

460	

8,015	

32	

8,047	

10	

10	

Securities held to maturity:

Corporate	and	other	debt

Total securities held to maturity 

$	

$	

10	 $	

10	 $	

—	 $	

—	 $	

(a) SBA	interest-only	strips	were	recorded	at	elected	fair	value.	See	Note	24	-	Fair	Value	of	Assets	and	Liabilities	for	additional	information.
(b) Includes	$6.4	billion	of	securities	pledged	to	secure	public	deposits,	securities	sold	under	agreements	to	repurchase,	and	for	other	purposes.

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NOTE	3—INVESTMENT	SECURITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

The	amortized	cost	and	fair	value	by	contractual	maturity	for	the	debt	securities	portfolio	as	of	December	31,	2021	is	provided	
below:

Table	8.3.2

DEBT	SECURITIES	PORTFOLIO	MATURITIES 

(Dollars	in	millions)
Within	1	year

After	1	year	through	5	years

After	5	years	through	10	years

After	10	years

Subtotal

Held	to	Maturity

Available	for	Sale

Amortized
Cost

Fair
Value

Amortized
Cost

Fair
Value

$	

—	 $	

—	 $	

17	 $	

—	

—	

—	

—	

—	

—	

—	

—	

705	

149	

351	

879	

1,396	

7,358	

705	 $	

8,754	 $	

18	

149	

349	

879	

1,395	

7,312	

8,707	

Government	agency	issued	MBS	and	CMO	(a)

Total

$	

712	

712	 $	

(a) Expected	maturities	will	differ	from	contractual	maturities	because	borrowers	may	have	the	right	to	call	or	prepay	obligations	with	or	without	call	or	

prepayment	penalties.

Gross	gains	on	sales	of	AFS	securities	for	the	years	ended	
December	31,	2021,	2020	and	2019	were	insignificant.	
Gross	losses	on	sales	of	AFS	securities	were	insignificant	
for	the	year	ended	December	31,	2021,		$4	million	for	the	
year	ended	2020,	and	insignificant	for	the	year	ended	
December	31,	2019.	Cash	proceeds	from	the	sales	of	AFS	

Table	8.3.3a

securities	during	2021,	2020	and	2019	were	$68	million,		
$629	million,	and	$192	million,	respectively.		

The	following	tables	provide	information	on	investments	
within	the	available-for-sale	portfolio	that	had	unrealized	
losses	as	of	December	31,	2021	and	2020:

AFS	INVESTMENT	SECURITIES	WITH	UNREALIZED	LOSSES	AT	YE	2021	

As	of	December	31,	2021

Less	than	12	months

12	months	or	longer

Total

Fair	Value

Unrealized	
Losses

Fair	Value

Unrealized	
Losses

Fair	Value

Unrealized	
Losses

$	

2,973	 $	

(41)	 $	

184	 $	

(8)	 $	

3,157	 $	

1,436	

459	

68	

(37)	

(11)	

(1)	

248	

90	

—	

(10)	

(4)	

—	

1,684	

549	

68	

(49)	

(47)	

(15)	

(1)	

$	

4,936	 $	

(90)	 $	

522	 $	

(22)	 $	

5,458	 $	

(112)	

(Dollars	in	millions)
Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities

Total

Table	8.3.3b

AFS	INVESTMENT	SECURITIES	WITH	UNREALIZED	LOSSES	AT	YE	2020	

(Dollars	in	millions)
U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities	

Total

Less	than	12	months

As	of	December	31,	2020
12	months	or	longer

Total

Fair	Value

Unrealized	
Losses

Fair	Value

Unrealized	
Losses

Fair	Value

Unrealized	
Losses

$	

307	 $	

—	 $	

—	 $	

—	 $	

307	 $	

426	

586	

80	

1	

(2)	

(3)	

(1)	

—	

—	

—	

—	

—	

—	

—	

—	

—	

426	

586	

80	

1	

$	

1,400	 $	

(6)	 $	

—	 $	

—	 $	

1,400	 $	

—	

(2)	

(3)	

(1)	

—	

(6)	

FHN	has	evaluated	all	AFS	debt	securities	that	were	in	
unrealized	loss	positions	in	accordance	with	its	accounting	

policy	for	recognition	of	credit	losses.	No	AFS	debt	
securities	were	determined	to	have	credit	losses	because	

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NOTE	3—INVESTMENT	SECURITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

the	primary	cause	of	the	decline	in	value	was	attributable	
to	changes	in	interest	rates.	Total	AIR	not	included	in	the	
fair	value	or	amortized	cost	basis	of	AFS	debt	securities	
was	$23	million	and	$22	million	as	of	December	31,	2021	
and	2020,	respectively.	Consistent	with	FHN's	review	of	
the	related	securities,	there	were	no	credit-related	write	
downs	of	AIR	for	AFS	debt	securities	during	the	reporting	
period.	Additionally,	for	AFS	debt	securities	with	
unrealized	losses,	FHN	does	not	intend	to	sell	them	and	it	
is	more-likely-than-not	that	FHN	will	not	be	required	to	
sell	them	prior	to	recovery.	Therefore,	no	write	downs	of	
these	investments	to	fair	value	occurred	during	the	
reporting	period.	

For	HTM	securities,	an	allowance	for	credit	losses	is	
required	to	absorb	estimated	lifetime	credit	losses.	Total	
AIR	not	included	in	the	fair	value	or	amortized	cost	basis	
of	HTM	debt	securities	was	$1	million	as	of	December	31,	
2021.	FHN	has	assessed	the	risk	of	credit	loss	and	has	
determined	that	zero	allowance	for	credit	losses	for	HTM	

securities	was	necessary	as	of	December	31,	2021	and	
2020.	The	evaluation	of	credit	risk	includes	consideration	
of	third-party	and	government	guarantees	(both	explicit	
and	implicit),	senior	or	subordinated	status,	credit	ratings	
of	the	issuer,	the	effects	of	interest	rate	changes	since	
purchase	and	observable	market	information	such	as	
issuer-specific	credit	spreads.

The	carrying	amount	of	equity	investments	without	a	
readily	determinable	fair	value	was	$70	million	and	$57	
million	at	December	31,	2021	and	2020,	respectively.	The	
year-to-date	2021	and	2020	gross	amounts	of	upward	and	
downward	valuation	adjustments	were	not	significant.

Unrealized	gains	of	$3	million	and	$7	million	were	
recognized	during	2021	and	2020,	respectively,	for	equity	
investments	with	readily	determinable	fair	values.

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NOTE	4—LOANS	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 4—Loans and Leases

The	loan	and	lease	portfolio	is	disaggregated	into	portfolio	
segments	and	then	further	disaggregated	into	classes	for	
certain	disclosures.	GAAP	defines	a	portfolio	segment	as	
the	level	at	which	an	entity	develops	and	documents	a	
systematic	method	for	determining	its	allowance	for	
credit	losses.	A	class	is	generally	a	disaggregation	of	a	
portfolio	segment	and	is	generally	determined	based	on	
risk	characteristics	of	the	loan	and	FHN’s	method	for	
monitoring	and	assessing	credit	risk	and	performance.	
FHN's	loan	and	lease	portfolio	segments	are	commercial	
and	consumer.	The	classes	of	loans	and	leases	are:	(1)	
commercial,	financial,	and	industrial,	which	includes	

commercial	and	industrial	loans	and	leases	and	loans	to	
mortgage	companies,	(2)	commercial	real	estate,	(3)	
consumer	real	estate,	which	includes	both	real	estate	
installment	and	home	equity	lines	of	credit,	and	(4)	credit	
card	and	other.	

The	following	table	provides	the	amortized	cost	basis	of	
loans	and	leases	by	portfolio	segment	and	class	as	of	
December	31,	2021	and	2020,	excluding	accrued	interest	
of	$134	million	and	$180	million,	respectively,	which	is	
included	in	other	assets	in	the	Consolidated	Balance	
Sheets.		

LOANS	AND	LEASES	BY	PORTFOLIO	SEGMENT

Table	8.4.1

(Dollars	in	millions)
Commercial:

Commercial	and	industrial	(a)	(b)

Loans	to	mortgage	companies

			Total	commercial,	financial,	and	industrial

Commercial	real	estate

Consumer:
HELOC

Real	estate	installment	loans

			Total	consumer	real	estate

Credit	card	and	other

Loans	and	leases
Allowance	for	loan	and	lease	losses

Net	loans	and	leases

December 31,

2021

2020

$	

26,550	 $	

4,518	

31,068	

12,109	

1,964	

8,808	

10,772	

910	
54,859	 $	
(670)	
54,189	 $	

$	

$	

27,700	

5,404	

33,104	

12,275	

2,420	

9,305	

11,725	

1,128	

58,232	

(963)	

57,269	

(a) Includes	equipment	financing	leases	of	$792	million	and	$587	million,	respectively,	as	of	December	31,	2021	and	2020.
(b)			Includes	PPP	loans	fully	guaranteed	by	the	SBA	of	$1.0	billion	and	$4.1	billion	as	of	December	31,	2021	and	2020.

Restrictions

Loans	and	leases	with	carrying	values	of	$36.6	billion	and	
$38.6	billion	were	pledged	as	collateral	for	borrowings	at	
December	31,	2021	and	2020,	respectively.

At	December	31,	2021	and	2020,	FHN	had	pledged	
$6.9	billion	and	$7.8	billion	of	commercial	loans	to	secure	
potential	discount	window	borrowings	from	the	Federal	
Reserve	Bank,	which	included	all	of	its	first	and	second	
lien	mortgages,	HELOCs,	and	commercial	real	estate	loans	
to	secure	potential	borrowings	from	the	FHLB-Cincinnati.	

Concentrations	of	Credit	Risk

Most	of	the	FHN’s	business	activity	is	with	clients	located	
in	the	southern	United	States.	FHN’s	lending	activity	is	
concentrated	in	its	market	areas	within	those	states.	As	of	
December	31,	2021,	FHN	had	loans	to	mortgage	
companies	totaling	$4.5	billion	and	loans	to	finance	and	
insurance	companies	total	$3.5	billion.	As	a	result,	26%	of	

the	C&I	segment	is	sensitive	to	impacts	on	the	financial	
services	industry.

Credit	Quality	Indicators

FHN	employs	a	dual	grade	commercial	risk	grading	
methodology	to	assign	an	estimate	for	the	probability	of	
default	and	the	loss	given	default	for	each	commercial	
loan	using	factors	specific	to	various	industry,	portfolio,	or	
product	segments	that	result	in	a	rank	ordering	of	risk	and	
the	assignment	of	grades	PD	1	to	PD	16.	This	credit	
grading	system	is	intended	to	identify	and	measure	the	
credit	quality	of	the	loan	and	lease	portfolio	by	analyzing	
the	migration	between	grading	categories.	It	is	also	
integral	to	the	estimation	methodology	utilized	in	
determining	the	ALLL	since	an	allowance	is	established	for	
pools	of	commercial	loans	based	on	the	credit	grade	
assigned.	Each	PD	grade	corresponds	to	an	estimated	one-
year	default	probability	percentage.	PD	grades	are	
continually	evaluated,	but	require	a	formal	scorecard	
annually.	As	a	response	to	the	COVID-19	pandemic,	FHN	

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NOTE	4—LOANS	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

identified	a	segment	of	its	commercial	portfolio	that	
required	a	quarterly	re-grading	process.	As	borrowers	
recover,	they	can	be	removed	from	the	quarterly	re-
grading	process	with	credit	officer	concurrence.	

PD	1	through	PD	12	are	“pass”	grades.	PD	grades	13-16	
correspond	to	the	regulatory-defined	categories	of	special	
mention	(13),	substandard	(14),	doubtful	(15),	and	loss	
(16).	Special	mention	commercial	loans	and	leases	have	
potential	weaknesses	that,	if	left	uncorrected,	may	result	
in	deterioration	of	FHN's	credit	position	at	some	future	
date.	Substandard	commercial	loans	and	leases	have	well-
defined	weaknesses	and	are	characterized	by	the	distinct	

Table	8.4.2a

possibility	that	FHN	will	sustain	some	loss	if	the	
deficiencies	are	not	corrected.	Doubtful	commercial	loans	
and	leases	have	the	same	weaknesses	as	substandard	
loans	and	leases	with	the	added	characteristics	that	the	
probability	of	loss	is	high	and	collection	of	the	full	amount	
is	improbable.

The	following	tables	provide	the	amortized	cost	basis	of	
the	commercial	loan	and	lease	portfolio	by	year	of	
origination	and	credit	quality	indicator	as	of	December	31,	
2021	and	2020:	

C&I	PORTFOLIO	AT	YE	2021

December	31,	2021

(Dollars	in	millions)

2021

2020

2019

2018

2017

Credit	Quality	Indicator:

Prior	to	
2017

LMC	(a)

Revolving
	Loans

Revolving	
Loans	Converted
to	Term	Loans	
(b)

Total

Pass	(PD	grades	1	through	12)	(c)

$	 7,372	

$	 3,576	

$	 3,439	

$	 1,455	

$	 1,193	

$	 2,267	

$	 4,518	

$	

6,386	 $	

13	 $	

30,219	

Special	Mention	(PD	grade	13)

Substandard,	Doubtful,	or	Loss	(PD	
grades	14,15,	and	16)

25	

24	

39	

61	

50	

67	

48	

103	

36	

24	

43	

48	

—	

—	

100	

129	

4	

48	

345	

504	

Total	C&I

$	 7,421	

$	 3,676	

$	 3,556	

$	 1,606	

$	 1,253	

$	 2,358	

$	 4,518	

$	

6,615	 $	

65	 $	

31,068	

(a) LMC	includes	non-revolving	commercial	lines	of	credit	to	qualified	mortgage	companies	primarily	for	the	temporary	warehousing	of	eligible	mortgage	

loans	prior	to	the	borrower's	sale	of	those	mortgage	loans	to	third	party	investors.	The	loans	are	of	short	duration	with	maturities	less	than	one	year.

(b)	 C&I	loans	converted	from	revolving	to	term	in	2021	were	not	material.
(c)	 Includes	PPP	loans.

Table	8.4.2b

C&I	PORTFOLIO	AT	YE	2020

December	31,	2020

(Dollars	in	millions)

2020

2019

2018

2017

2016

Credit	Quality	Indicator:

Prior	to	
2016

LMC	(a)

Revolving
	Loans

Revolving	
Loans	Converted
to	Term	Loans	
(b)

Total

Pass	(PD	grades	1	through	12)	(c)

$	 9,060	 $	 5,138	 $	 2,628	 $	 1,748	 $	 1,161	 $	 2,145	 $	 5,404	 $	

4,571	 $	

60	 $	

31,915	

Special	Mention	(PD	grade	13)

Substandard,	Doubtful,	or	Loss	(PD	
grades	14,15,	and	16)

89	

182	

93	

77	

70	

114	

31	

50	

37	

42	

64	

58	

—	

—	

127	

95	

1	

59	

512	

677	

Total	C&I

$	 9,331	 $	 5,308	 $	 2,812	 $	 1,829	 $	 1,240	 $	 2,267	 $	 5,404	 $	

4,793	 $	

120	 $	

33,104	

(a) LMC	includes	non-revolving	commercial	lines	of	credit	to	qualified	mortgage	companies	primarily	for	the	temporary	warehousing	of	eligible	mortgage	

loans	prior	to	the	borrower's	sale	of	those	mortgage	loans	to	third	party	investors.	The	loans	are	of	short	duration	with	maturities	less	than	one	year.

(b) $50	million	of	C&I	loans	were	converted	from	revolving	to	term	in	2020.
(c)	 Includes	PPP	loans.

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Table	8.4.2c

(Dollars	in	millions)

Credit	Quality	Indicator:

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	4—LOANS	&	LEASES

CRE	PORTFOLIO	AT	YE	2021

December	31,	2021

2021

2020

2019

2018

2017

Prior	to	
2017

Revolving
	Loans

Revolving
Loans	Converted
to	Term	Loans

Total

Pass	(PD	grades	1	through	12)

$	 3,441	 $	 2,065	 $	 2,514	 $	

929	 $	

691	 $	 1,822	 $	

204	 $	

—	 $	

Special	Mention	(PD	grade	13)

Substandard,	Doubtful,	or	Loss	(PD	grades	
14,15,	and	16)

4	

47	

26	

—	

52	

24	

125	

3	

20	

33	

65	

32	

—	

12	

—	

—	

Total	CRE

$	 3,492	 $	 2,091	 $	 2,590	 $	 1,057	 $	

744	 $	 1,919	 $	

216	 $	

—	 $	

11,666	

292	

151	

12,109	

Table	8.4.2d

CRE	PORTFOLIO	AT	YE	2020

December	31,	2020

(Dollars	in	millions)

2020

2019

2018

2017

2016

Credit	Quality	Indicator:

Prior	to	
2016

Revolving
	Loans

Revolving
Loans	Converted
to	Term	Loans

Total

Pass	(PD	grades	1	through	12)

$	 2,477	

$	 3,311	

$	 1,750	

$	 1,140	 $	

946	 $	 1,800	 $	

259	 $	

19	 $	

11,702	

Special	Mention	(PD	grade	13)

Substandard,	Doubtful,	or	Loss	(PD	grades	
14,15,	and	16)

48	

30	

24	

13	

117	

21	

75	

42	

71	

27	

54	

33	

—	

18	

—	

—	

389	

184	

Total	CRE

$	 2,555	

$	 3,348	

$	 1,888	

$	 1,257	 $	 1,044	 $	 1,887	 $	

277	 $	

19	 $	

12,275	

The	consumer	portfolio	is	comprised	primarily	of	smaller-
balance	loans	which	are	very	similar	in	nature	in	that	most	
are	standard	products	and	are	backed	by	residential	real	
estate.	Because	of	the	similarities	of	consumer	loan	types,	
FHN	is	able	to	utilize	the	FICO	score,	among	other	
attributes,	to	assess	the	credit	quality	of	consumer	
borrowers.	FICO	scores	are	refreshed	on	a	quarterly	basis	
in	an	attempt	to	reflect	the	recent	risk	profile	of	the	
borrowers.	Accruing	delinquency	amounts	are	indicators	
of	asset	quality	within	the	credit	card	and	other	consumer	
portfolio.

The	following	tables	reflect	the	amortized	cost	basis	by	
year	of	origination	and	refreshed	FICO	scores	for	

Table	8.4.3a

consumer	real	estate	loans	as	of	December	31,	2021	and	
2020.	Within	consumer	real	estate,	classes	include	HELOC	
and	real	estate	installment	loans.	HELOCs	are	loans	which	
during	their	draw	period	are	classified	as	revolving	loans.	
Once	the	draw	period	ends	and	the	loan	enters	its	
repayment	period,	the	loan	converts	to	a	term	loan	and	is	
classified	as	revolving	loans	converted	to	term	loans.	All	
loans	classified	in	the	following	table	as	revolving	loans	or	
revolving	loans	converted	to	term	loans	are	HELOCs.	Real	
estate	installment	loans	are	originated	as	fixed	term	loans	
and	are	classified	below	in	their	vintage	year.	All	loans	in	
the	following	tables	classified	in	a	vintage	year	are	real	
estate	installment	loans.

CONSUMER	REAL	ESTATE	PORTFOLIO	AT	YE	2021

December	31,	2021

(Dollars	in	millions)

2021

2020

2019

2018

2017

Prior	to	
2017

Revolving		
loans

Revolving	
Loans	
converted	
to	term	
loans	(a)

Total

FICO	score	740	or	greater

$	

1,594	 $	

1,156	 $	

825	 $	

473	 $	

394	 $	

1,335	 $	

1,086	 $	

115	 $	

6,978	

FICO	score	720-739

FICO	score	700-719

FICO	score	660-699

FICO	score	620-659

FICO	score	less	than	620

236	

143	

164	

42	

26	

171	

112	

131	

36	

84	

109	

81	

120	

55	

42	

61	

68	

106	

23	

32	

44	

45	

44	

13	

45	

209	

153	

246	

118	

272	

162	

141	

204	

66	

42	

21	

23	

44	

27	

33	

1,013	

766	

1,059	

380	

576	

Total

$	

2,205	 $	

1,690	 $	

1,232	 $	

763	 $	

585	 $	

2,333	 $	

1,701	 $	

263	 $	 10,772	

(a) $43	million	of	HELOC	loans	were	converted	from	revolving	to	term	in	2021.

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Table	8.4.3b

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	4—LOANS	&	LEASES

CONSUMER	REAL	ESTATE	PORTFOLIO	AT	YE	2020

December	31,	2020

(Dollars	in	millions)

2020

2019

2018

2017

2016

Prior	to	
2016

Revolving		
loans

Revolving	
Loans	
converted	
to	term	
loans	(a)

Total

FICO	score	740	or	greater

$	

1,186	 $	

1,167	 $	

703	 $	

610	 $	

674	 $	

1,719	 $	

1,275	 $	

159	 $	

7,493	

FICO	score	720-739

FICO	score	700-719

FICO	score	660-699

FICO	score	620-659

FICO	score	less	than	620

157	

122	

130	

45	

107	

158	

107	

141	

61	

36	

100	

78	

123	

37	

52	

77	

76	

75	

28	

54	

92	

73	

85	

35	

95	

197	

221	

296	

127	

261	

186	

177	

264	

92	

61	

29	

34	

59	

36	

48	

996	

888	

1,173	

461	

714	

Total

$	

1,747	 $	

1,670	 $	

1,093	 $	

920	 $	

1,054	 $	

2,821	 $	

2,055	 $	

365	 $	 11,725	

(a)	 $36	million	of	HELOC	loans	were	converted	from	revolving	to	term	in	2020.

The	following	tables	reflect	the	amortized	cost	basis	by	year	of	origination	and	refreshed	FICO	scores	for	credit	card	and	other	
loans	as	of	December	31,	2021	and	2020.

Table	8.4.4a

CREDIT	CARD	&	OTHER	PORTFOLIO	AT	YE	2021

December	31,	2021

(Dollars	in	millions)

2021

2020

2019

2018

2017

Prior	to	
2017

Revolving		
loans

Revolving	
Loans	
converted	
to	term	
loans

Total

FICO	score	740	or	greater

$	

56	 $	

35	 $	

29	 $	

23	 $	

13	 $	

56	 $	

200	 $	

11	 $	

423	

FICO	score	720-739

FICO	score	700-719

FICO	score	660-699

FICO	score	620-659

FICO	score	less	than	620

14	

8	

25	

4	

24	

5	

5	

6	

3	

3	

4	

4	

5	

2	

3	

3	

4	

6	

4	

4	

4	

3	

4	

3	

4	

17	

17	

31	

18	

16	

46	

42	

98	

22	

18	

3	

1	

2	

1	

1	

96	

84	

177	

57	

73	

Total

$	

131	 $	

57	 $	

47	 $	

44	 $	

31	 $	

155	 $	

426	 $	

19	 $	

910	

(a)	$9	million	of	other	consumer	loans	were	converted	from	revolving	to	term	in	2021.

Table	8.4.4b

CREDIT	CARD	&	OTHER	PORTFOLIO	AT	YE	2020

December	31,	2020

(Dollars	in	millions)

2020

2019

2018

2017

2016

Prior	to	
2016

Revolving		
loans

Revolving	
Loans	
converted	
to	term	
loans

FICO	score	740	or	greater

$	

57	 $	

52	 $	

59	 $	

37	 $	

23	 $	

116	 $	

159	 $	

5	 $	

FICO	score	720-739

FICO	score	700-719

FICO	score	660-699

FICO	score	620-659

FICO	score	less	than	620

7	

9	

30	

5	

14	

7	

8	

12	

5	

7	

9	

9	

15	

7	

8	

8	

8	

9	

5	

11	

8	

4	

9	

10	

9	

27	

38	

48	

24	

26	

91	

37	

46	

20	

20	

2	

3	

3	

1	

1	

Total

508	

159	

116	

172	

77	

96	

Total

$	

122	 $	

91	 $	

107	 $	

78	 $	

63	 $	

279	 $	

373	 $	

15	 $	

1,128	

Nonaccrual	and	Past	Due	Loans	and	Leases
Loans	and	leases	are	placed	on	nonaccrual	if	it	becomes	
evident	that	full	collection	of	principal	and	interest	is	at	

risk,	impairment	has	been	recognized	as	a	partial	charge-
off	of	principal	balance	due	to	insufficient	collateral	value	
and	past	due	status,	or	on	a	case-by-case	basis	if	FHN	

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NOTE	4—LOANS	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

continues	to	receive	payments	but	there	are	other	
borrower-specific	issues.		Included	in	nonaccrual	are	loans	
for	which	FHN	continues	to	receive	payments	including	
residential	real	estate	loans	where	the	borrower	has	been	
discharged	of	personal	obligation	through	bankruptcy.	

Past	due	loans	are	loans	contractually	past	due	as	to	
interest	or	principal	payments,	but	which	have	not	yet	
been	put	on	nonaccrual	status.	In	accordance	with	revised	
Interagency	Guidance	issued	in	2020,	FHN	is	not	required	
to	designate	loans	with	deferrals	granted	in	response	to	
COVID-19	as	past	due	because	of	such	deferrals.	If	a	

Table	8.4.5a

borrower	defers	payment,	this	may	result	in	no	
contractual	payments	being	past	due,	and	as	such,	loans	
would	not	be	considered	past	due	during	the	period	of	
deferral,	and	as	a	result,	are	excluded	from	loans	past	due	
30-89	days	and	loans	90+	days	past	due	in	the	table	
below.	When	qualifying	COVID-19	deferral	periods	end,	
the	related	loans	are	subject	to	past	due	reporting.	

The	following	tables	reflect	accruing	and	non-accruing	
loans	and	leases	by	class	on	December	31,	2021	and	2020:

ACCRUING	&	NON-ACCRUING	LOANS	&	LEASES	AT	YE	2021

(Dollars	in	millions)

Current

Accruing

30-89
Days
Past	Due

90+
Days
Past	Due

December	31,	2021

Non-Accruing

Total
Accruing

Current

30-89
Days
Past	Due

90+
Days
Past	Due

Total
Non-
Accruing

Total
Loans

Commercial,	financial,	and	
industrial:
C&I	(a)	
Loans	to	mortgage	
companies
Total	commercial,	
financial,	and	industrial

Commercial	real	estate:

CRE	(b)

Consumer	real	estate:

HELOC	(c)
Real	estate	installment	
loans	(d)
Total	consumer	real	
estate

Credit	card	and	other:

Credit	card

Other
Total	credit	card	and	
other

$	

26,367	 $	

53	 $	

5	 $	

26,425	 $	

97	 $	

1	 $	

27	 $	

125	 $	

26,550	

4,518	

30,885	

12,087	

1,906	

8,658	

10,564	

292	

608	

900	

—	

53	

13	

7	

30	

37	

2	

3	

5	

—	

5	

—	

6	

27	

33	

2	

—	

2	

4,518	

30,943	

12,100	

1,919	

8,715	

10,634	

296	

611	

907	

—	

97	

6	

34	

44	

78	

—	

1	

1	

—	

1	

1	

2	

3	

5	

—	

—	

—	

—	

27	

2	

9	

46	

55	

—	

2	

2	

—	

125	

9	

45	

93	

4,518	

31,068	

12,109	

1,964	

8,808	

138	

10,772	

—	

3	

3	

296	

614	

910	

Total	loans	and	leases

$	

54,436	 $	

108	 $	

40	 $	

54,584	 $	

182	 $	

7	 $	

86	 $	

275	 $	

54,859	

(a) $99	million	of	C&I	loans	are	nonaccrual	loans	that	have	been	specifically	reviewed	for	impairment	with	no	related	allowance.
(b)	 $5	million	of	CRE	loans	are	nonaccrual	loans	that	have	been	specifically	reviewed	for	impairment	with	no	related	allowance.
(c)	 $7	million	of	HELOC	loans	are	nonaccrual	loans	that	have	been	specifically	reviewed	for	impairment	with	no	related	allowance.
(d)	 $50	million	of	real	estate	installment	loans	are	nonaccrual	loans	that	have	been	specifically	reviewed	for	impairment	with	no	related	allowance.

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Table	8.4.5b

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	4—LOANS	&	LEASES

ACCRUING	&	NON-ACCRUING	LOANS	&	LEASES	AT	YE	2020

(Dollars	in	millions)

Current

Accruing

30-89
Days
Past	Due

90+
Days
Past	Due

December	31,	2020

Non-Accruing

Total
Accruing

Current

30-89
Days
Past	Due

90+
Days
Past	Due

Total
Non-
Accruing

Total
Loans

Commercial,	financial,	and	
industrial:
C&I	(a)
Loans	to	mortgage	
companies
Total	commercial,	
financial,	and	industrial

Commercial	real	estate:

CRE	(b)

Consumer	real	estate:

HELOC
Real	estate	installment	
loans
Total	consumer	real	
estate

Credit	card	and	other:

Credit	card

Other
Total	credit	card	and	
other

$	

27,541	 $	

15	 $	

—	 $	

27,556	 $	

88	 $	

12	 $	

44	 $	

144	 $	

27,700	

5,404	

32,945	

12,194	

2,336	

9,138	

11,474	

279	

838	

1,117	

—	

15	

23	

13	

40	

53	

3	

6	

9	

—	

—	

—	

11	

5	

16	

1	

—	

1	

5,404	

32,960	

12,217	

2,360	

9,183	

—	

88	

10	

43	

63	

11,543	

106	

283	

844	

1,127	

—	

1	

1	

—	

12	

42	

3	

9	

12	

—	

—	

—	

—	

44	

6	

14	

50	

64	

—	

1	

1	

—	

144	

58	

60	

122	

182	

—	

2	

2	

5,404	

33,104	

12,275	

2,420	

9,305	

11,725	

283	

845	

1,128	

Total	loans	and	leases

$	

57,730	 $	

100	 $	

17	 $	

57,847	 $	

205	 $	

66	 $	

115	 $	

386	 $	

58,232	

(a)	 $101	million	of	C&I	loans	are	nonaccrual	loans	that	have	been	specifically	reviewed	for	impairment	with	no	related	allowance.

Collateral-Dependent	Loans

Collateral-dependent	loans	are	defined	as	loans	for	which	
repayment	is	expected	to	be	derived	substantially	through	
the	operation	or	sale	of	the	collateral	and	where	the	
borrower	is	experiencing	financial	difficulty.	At	a	
minimum,	the	estimated	value	of	the	collateral	for	each	
loan	equals	the	current	book	value.	

As	of	December	31,	2021	and	2020,	FHN	had	commercial	
loans	with	amortized	cost	of	approximately	$120	million	
and	$167	million,	respectively,	that	were	based	on	the	
value	of	underlying	collateral.	Collateral-dependent	C&I	
and	CRE	loans	totaled	$115	million	and	$5	million,	
respectively,	at	December	31,	2021.	The	collateral	for	
these	loans	generally	consists	of	business	assets	including	
land,	buildings,	equipment	and	financial	assets.	During	the	
years	ended	December	31,	2021	and	2020,	FHN	
recognized	total	charge-offs	of	approximately	$26	million	
and	$36	million,	respectively,	on	these	loans	related	to	
reductions	in	estimated	collateral	values.

Consumer	HELOC	and	installment	loans	with	amortized	
cost	based	on	the	value	of	underlying	real	estate	collateral	
were	approximately	$7	million	and	$20	million,	
respectively,	as	of	December	31,	2021,	and	$9	million	and	
$26	million,	respectively,	as	of	December	31,	2020.	
Charge-offs	on	collateral-dependent	consumer	loans	were	
$1	million	during	the	year	ended	December	31,	2021,	and	

were	not	significant	during	the	year	ended	December	31,	
2020.	

Troubled	Debt	Restructurings

As	part	of	FHN’s	ongoing	risk	management	practices,	FHN	
attempts	to	work	with	borrowers	when	necessary	to	
extend	or	modify	loan	terms	to	better	align	with	their	
current	ability	to	repay.	Extensions	and	modifications	to	
loans	are	made	in	accordance	with	internal	policies	and	
guidelines	which	conform	to	regulatory	guidance.	Each	
occurrence	is	unique	to	the	borrower	and	is	evaluated	
separately.

A	modification	is	classified	as	a	TDR	if	the	borrower	is	
experiencing	financial	difficulty	and	it	is	determined	that	
FHN	has	granted	a	concession	to	the	borrower.	FHN	may	
determine	that	a	borrower	is	experiencing	financial	
difficulty	if	the	borrower	is	currently	in	default	on	any	of	
its	debt,	or	if	it	is	probable	that	a	borrower	may	default	in	
the	foreseeable	future.	Many	aspects	of	a	borrower’s	
financial	situation	are	assessed	when	determining	
whether	they	are	experiencing	financial	difficulty.	
Concessions	could	include	extension	of	the	maturity	date,	
reductions	of	the	interest	rate	(which	may	make	the	rate	
lower	than	current	market	for	a	new	loan	with	similar	
risk),	reduction	or	forgiveness	of	accrued	interest,	or	
principal	forgiveness.	The	assessments	of	whether	a	
borrower	is	experiencing	(or	is	likely	to	experience)	

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NOTE	4—LOANS	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

financial	difficulty,	and	whether	a	concession	has	been	
granted,	are	subjective	in	nature	and	management’s	
judgment	is	required	when	determining	whether	a	
modification	is	classified	as	a	TDR.	In	accordance	with	
regulatory	guidance,	loans	were	not	accounted	for	as	
TDRs	and	have	been	excluded	from	the	disclosures	below.	
For	loan	modifications	that	were	made	during	the	years	
ended	December	31,	2021	and	2020	that	met	the	TDR	
relief	provisions	outlined	in	either	the	CARES	Act,	as	
extended	by	the	CAA,	or	revised	Interagency	Guidance,	
FHN	has	excluded	these	modifications	from	consideration	
as	TDRs,	and	has	excluded	loans	with	these	qualifying	
modifications	from	designation	as	a	TDR	in	the	
information	and	discussion	that	follows.	See	Note	1	-	
Significant	Accounting	Policies	for	further	discussion	
regarding	TDRs	and	loan	modifications.

For	all	classes	within	the	commercial	portfolio	segment,	
TDRs	are	typically	modified	through	forbearance	
agreements	(generally	6	to	12	months).	Forbearance	
agreements	could	include	reduced	interest	rates,	reduced	
payments,	release	of	guarantor,	or	entering	into	short	sale	
agreements.	

FHN’s	proprietary	modification	programs	for	consumer	
loans	are	generally	structured	using	parameters	of	U.S.	
government-sponsored	programs	such	as	the	former	
Home	Affordable	Modification	Program.	Within	the	
HELOC	and	real	estate	installment	loans	classes	of	the	
consumer	portfolio	segment,	TDRs	are	typically	modified	
by	reducing	the	interest	rate	(in	increments	of	25	basis	
points	to	a	minimum	of	1%	for	up	to	5	years)	and	a	
possible	maturity	date	extension	to	reach	an	affordable	
housing	debt-to-income	ratio.	After	5	years,	the	interest	
rate	generally	returns	to	the	original	interest	rate	prior	to	
modification;	for	certain	modifications,	the	modified	
interest	rate	increases	2%	per	year	until	the	original	

Table	8.4.6

interest	rate	prior	to	modification	is	achieved.	Mortgage	
TDRs	are	typically	modified	by	reducing	the	interest	rate	
(in	increments	of	25	basis	points	to	a	minimum	of	2%	for	
up	to	5	years)	and	a	possible	maturity	date	extension	to	
reach	an	affordable	housing	debt-to-income	ratio.	After	5	
years,	the	interest	rate	steps	up	1%	every	year	until	it	
reaches	the	Federal	Home	Loan	Mortgage	Corporation	
Weekly	Survey	Rate	cap.	Contractual	maturities	may	be	
extended	to	40	years	on	permanent	mortgages	and	to	30	
years	for	consumer	real	estate	loans.	

Within	the	credit	card	class	of	the	consumer	portfolio	
segment,	TDRs	are	typically	modified	through	either	a	
short-term	credit	card	hardship	program	or	a	longer-term	
credit	card	workout	program.	In	the	credit	card	hardship	
program,	borrowers	may	be	granted	rate	and	payment	
reductions	for	6	months	to	1	year.	In	the	credit	card	
workout	program,	clients	are	granted	a	rate	reduction	to	
0%	and	term	extensions	for	up	to	5	years	to	pay	off	the	
remaining	balance.

Despite	the	absence	of	a	loan	modification,	the	discharge	
of	personal	liability	through	bankruptcy	proceedings	is	
considered	a	concession.	As	a	result,	FHN	classifies	all	non-
reaffirmed	residential	real	estate	loans	discharged	in	
Chapter	7	bankruptcy	as	nonaccruing	TDRs.

On	December	31,	2021	and	2020,	FHN	had	$206	million	
and	$307	million	of	portfolio	loans	classified	as	TDRs,	
respectively.	Additionally,	$35	million	and	$42	million	of	
loans	held	for	sale	as	of	December	31,	2021	and	2020,	
respectively,	were	classified	as	TDRs.

The	following	table	presents	the	end	of	period	balance	for	
loans	modified	in	a	TDR	during	the	years	ended	
December	31,	2021	and	2020:

LOANS	MODIFIED	IN	A	TDR

2021

2020

Pre-Modification
Outstanding
Recorded	Investment

Number

Post-Modification
Outstanding

Recorded	Investment Number

Pre-Modification
Outstanding
Recorded	Investment

Post-Modification
Outstanding
Recorded	Investment

(Dollars	in	millions)
C&I

CRE

HELOC

Real	estate	installment	loans

Credit	card	and	other

32	 $	

37	 $	

1	

25	

87	

51	

12	

3	

14	

—	

Total	TDRs

196	 $	

66	 $	

34	

10	

3	

14	

—	

61	

112	 $	

195	 $	

19	

64	

117	

56	

15	

5	

20	

1	

368	 $	

236	 $	

188	

15	

5	

19	

1	

228	

The	following	table	presents	TDRs	which	re-defaulted	during	2021	and	2020,	and	as	to	which	the	modification	occurred	12	
months	or	less	prior	to	the	re-default.	For	purposes	of	this	disclosure,	FHN	generally	defines	payment	default	as	30	or	more	
days	past	due.

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Table	8.4.7

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	4—LOANS	&	LEASES

LOANS	MODIFIED	IN	A	TDR	THAT	RE-DEFAULTED

(Dollars	in	millions)

Number

C&I
CRE

HELOC

Real	estate	installment	loans

Credit	card	and	other

Total	TDRs

2021

18	 $	

6	

1	

9	

4	

38	 $	

Recorded
Investment

Number

5	

19	

—	

5	

—	

29	

2020

9	 $	

—	

8	

18	

24	

59	 $	

Recorded
Investment

1	

—	

—	

1	

—	

2	

Note 5—Allowance for Credit Losses

Management's	estimate	of	expected	credit	losses	in	the	
loan	and	lease	portfolios	is	recorded	in	the	ALLL	and	the	
reserve	for	unfunded	lending	commitments,	collectively	
the	ACL.	See	Note	1	-	Significant	Accounting	Policies	for	
further	discussion	of	FHN's	ACL	methodology.

The	ACL	is	maintained	at	a	level	management	believes	to	
be	appropriate	to	absorb	expected	lifetime	credit	losses	
over	the	contractual	life	of	the	loan	and	lease	portfolio	
and	unfunded	lending	commitments.	The	determination	
of	the	ACL	is	based	on	periodic	evaluation	of	the	loan	and	
lease	portfolios	and	unfunded	lending	commitments	
considering	a	number	of	relevant	underling	factors,	
including	key	assumptions	and	evaluation	of	quantitative	
and	qualitative	information.	

The	expected	loan	losses	are	the	product	of	multiplying	
FHN’s	estimates	of	probability	of	default	(PD),	loss	given	
default	(LGD),	and	individual	loan	level	exposure	as	
default	(EAD),	including	amortization	and	prepayment	
assumptions,	on	an	undiscounted	basis.		FHN	uses	models	
or	assumptions	to	develop	the	expected	loss	forecasts,	
which	incorporate	multiple	macroeconomic	forecasts	over	
a	four	year	reasonable	and	supportable	forecast	period.	
After	the	reasonable	and	supportable	forecast	period,	the	
Company	immediately	reverts	to	its	historical	loss	
averages,	evaluated	over	the	historical	observation	
period,	for	the	remaining	estimated	life	of	the	loans.	In	
order	to	capture	the	unique	risks	of	the	loan	portfolio	
within	the	PD,	LGD,	and	prepayment	models,	FHN	
segments	the	portfolio	into	pools,	generally	incorporating	
loan	grades	for	commercial	loans.	As	there	can	be	no	
certainty	that	actual	economic	performance	will	precisely	
follow	any	specific	macroeconomic	forecast,	FHN	uses	
qualitative	adjustments	to	adjust	historical	loss	
information	in	situations	where	current	loan	
characteristics	differ	from	those	in	the	historical	loss	
information	and	for	differences	in	economic	conditions	
and	other	factors.	

The	evaluation	of	quantitative	and	qualitative	information	
is	performed	through	assessments	of	groups	of	assets	that	
share	similar	risk	characteristics	and	certain	individual	
loans	and	leases	that	do	not	share	similar	risk	

characteristics	with	the	collective	group.	As	described	in	
Note	4	-	Loans	and	Leases,	loans	are	grouped	generally	by	
product	type	and	significant	loan	portfolios	are	assessed	
for	credit	losses	using	analytical	or	statistical	models.	The	
quantitative	evaluation	of	the	adequacy	of	the	ACL	utilizes	
a	weighting	approach	for	multiple	economic	forecast	
scenarios	as	its	foundation,	and	is	primarily	based	on	
analytical	models	that	use	known	or	estimated	data	as	of	
the	balance	sheet	date	and	forecasted	data	over	the	
reasonable	and	supportable	period.	The	ACL	may	also	be	
affected	by	a	variety	of	qualitative	factors	that	FHN	
considers	to	reflect	current	judgment	of	various	events	
and	risks	that	are	not	measured	in	the	quantitative	
calculations.

In	accordance	with	its	accounting	policy	elections,	FHN	
does	not	recognize	a	separate	allowance	for	expected	
credit	losses	for	AIR	and	records	reversals	of	AIR	as	
reductions	of	interest	income.	FHN	reverses	previously	
accrued	but	uncollected	interest	when	an	asset	is	placed	
on	nonaccrual	status.	As	of	December	31,	2021	and	2020,	
FHN	recognized	approximately	$1	million	in	allowance	for	
expected	credit	losses	on	COVID-19	deferrals	that	do	not	
qualify	for	the	election	which	is	not	reflected	in	the	table	
below.	AIR	and	the	related	allowance	for	expected	credit	
losses	is	included	as	a	component	of	other	assets.	The	
total	amount	of	interest	reversals	from	loans	placed	on	
nonaccrual	status	and	the	amount	of	income	recognized	
on	nonaccrual	loans	during	the	year	ended	December	31,	
2021	were	not	material.

Expected	credit	losses	for	unfunded	commitments	are	
estimated	for	periods	where	the	commitment	is	not	
unconditionally	cancellable.	The	measurement	of	
expected	credit	losses	for	unfunded	commitments	mirrors	
that	of	loans	and	leases	with	the	additional	estimate	of	
future	draw	rates	(timing	and	amount).

The	decrease	in	the	ACL	as	of	December	31,	2021	as	
compared	to	December	31,	2020	reflects	an	improvement	
in	the	macroeconomic	outlook,	positive	grade	migration,	
and	lower	loan	balances,	which	was	offset	slightly	by	
higher	C&I	loan	balances	excluding	PPP	loans.	

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NOTE	5—ALLOWANCE	FOR	CREDIT	LOSSES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

In	developing	credit	loss	estimates	for	its	loan	and	lease	
portfolios,	FHN	utilized	multiple	Moody’s	forecast	
scenarios	for	its	macroeconomic	inputs.	Each	scenario	
included	assumptions	around	the	COVID-19	pandemic	and	
its	impact	on	various	sections	of	the	economy.	The	
heaviest	weight	was	placed	on	the	baseline	forecast,	
which	assumed	positive	real	GDP	growth	over	the	forecast	
horizon	and	return	to	full	employment	by	year-end	2022.	

During	the	years	ended	December	31,	2021	and	2020,	
FHN	also	considered	stressed	loan	portfolios	or	industries	
that	are	most	exposed	to	the	effects	of	the	COVID-19	

pandemic	and	added	qualitative	adjustments,	where	
needed,	to	account	for	the	risks	not	captured	in	modeled	
results.	Management	also	made	qualitative	adjustments	
to	reflect	estimated	recoveries	based	on	a	review	of	prior	
charge	off	and	recovery	levels,	for	default	risk	associated	
with	large	balances	with	individual	borrowers,	for	
estimated	loss	amounts	not	reflected	in	historical	factors	
due	to	specific	portfolio	risk,	and	for	instances	where	
limited	data	for	acquired	loans	is	considered	to	affect	
modeled	results.

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NOTE	5—ALLOWANCE	FOR	CREDIT	LOSSES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

The	following	table	provides	a	rollforward	of	the	allowance	for	loan	and	lease	losses	and	the	reserve	for	unfunded	lending	
commitments	by	portfolio	type	for	December	31,	2021,	2020	and	2019:

Table	8.5.1

ROLLFORWARD	OF	ALLL	&	RESERVE	FOR	UNFUNDED	LENDING	COMMITMENTS

Commercial,	
Financial,	and	
Industrial	(a)

Commercial
Real	Estate

Consumer
Real	Estate

Credit	Card
and	Other

Total

$	

453	 $	

242	 $	

242	 $	

26	 $	

(Dollars	in	millions)

Allowance	for	loan	and	lease	losses:	
Balance	as	of	January	1,	2021
Charge-offs	
Recoveries
Provision	for	loan	and	lease	losses	

Balance	as	of	December	31,	2021

Reserve	for	remaining	unfunded	commitments:

Balance	as	of	January	1,	2021
Provision	for	unfunded	lending	commitments

Balance	as	of	December	31,	2021

Allowance	for	credit	losses	as	of	December	31,	2021

Allowance	for	loan	and	lease	losses:

Balance	as	of	January	1,	2020

Adoption	of	ASU	2016-13

Balance	as	of	January	1,	2020,	as	adjusted

Charge-offs	(b)

Recoveries	
Initial	allowance	on	loans	purchased	with	credit	
deterioration	(b)
Provision	for	loan	and	lease	losses	(c)

Balance	as	of	December	31,	2020

Reserve	for	remaining	unfunded	commitments:

Balance	as	of	January	1,	2020

Adoption	of	ASU	2016-13

Balance	as	of	January	1,	2020,	as	adjusted

Initial	reserve	on	loans	acquired

Provision	for	unfunded	lending	commitments

Balance	as	of	December	31,	2020

Allowance	for	credit	losses	as	of	December	31,	2020

Allowance	for	loan	losses

Balance	as	of	January	1,	2019

Charge-offs

Recoveries	

Provision	for	loan	losses	

Balance	as	of	December	31,	2019

Reserve	for	remaining	unfunded	commitments:

Balance	as	of	January	1,	2019

Provision	for	unfunded	lending	commitments

Balance	as	of	December	31,	2019

(34)	
21	

(106)	

334	

65	

(19)	

46	

(5)	
5	

(88)	

154	

10	

2	

12	

(5)	
27	

(101)	

163	

10	

(2)	

8	

(15)	
4	

4	

19	

—	

—	

—	

380	 $	

166	 $	

171	 $	

19	 $	

123	 $	

36	 $	

28	 $	

13	 $	

19	

142	

(129)	

9	

138	

293	

453	

4	

17	

21	

12	

32	

65	

(7)	

29	

(5)	

4	

100	

114	

242	

2	

1	

3	

26	

(19)	

10	

93	

121	

(8)	

18	

44	

67	

242	

—	

6	

6	

3	

1	

10	

2	

15	

(14)	

5	

5	

15	

26	

—	

—	

—	

—	

—	

—	

963	

(59)	
57	

(291)	

670	

85	

(19)	

66	

736	

200	

107	

307	

(156)	

36	

287	

489	

963	

6	

24	

30	

41	

14	

85	

518	 $	

252	 $	

252	 $	

26	 $	

1,048	

99	 $	

31	 $	

37	 $	

13	 $	

(34)	

7	

51	

123	

4	

—	

4	

(1)	

1	

5	

36	

3	

(1)	

2	

(8)	

20	

(21)	

28	

—	

—	

—	

(16)	

4	

12	

13	

—	

—	

—	

180	

(59)	

32	

47	

200	

7	

(1)	

6	

$	

$	

$	

$	

Allowance	for	credit	losses	as	of	December	31,	2019

$	

127	 $	

38	 $	

28	 $	

13	 $	

206	

(a)	 C&I	loans	as	of	December	31,	2021	and	2020	include	$1.0	billion	and	$4.1	billion	in	PPP	loans	which	due	to	the	government	guarantee	and	forgiveness	provisions	are	

considered	to	have	no	credit	risk	and	therefore	have	no	allowance	for	loan	and	lease	losses.

(b)	 The	year	ended	December	31,	2020	excludes	day	1	charge-offs	and	the	related	initial	allowance	on	PCD	loans	is	net	of	these	amounts.	Under	ASC	326,	the	initial	ALLL	

recognized	on	PCD	assets	included	an	additional	$237	million	for	charged-off	loans	that	had	been	written	off	prior	to	acquisition	(whether	full	or	partial)	or	which	met	FHN's	
charge-off	policy	at	the	time	of	acquisition.	After	charging	these	amounts	off	immediately	upon	acquisition,	the	net	impact	was	$287	million	of	additional	ALLL	for	PCD	loans.	

(c)	 Provision	for	loan	and	lease	losses	for	the	year	ended	December	31,	2020	includes	$147	million	recognized	on	non-PCD	loans	from	the	IBKC	merger	and	Truist	branch	

acquisition.	

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Table of Contents

NOTE	6—PREMISES,	EQUIPMENT,	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 6—Premises, Equipment, and Leases

Premises	and	equipment	were	comprised	of	the	following	
at	December	31,	2021	and	2020:	

Table	8.6.1

PREMISES	&	EQUIPMENT
December	31,	
2021

(Dollars	in	millions)

December	31,	
2020

Land

Buildings

Leasehold	improvements

Furniture,	fixtures,	and	equipment

Fixed	assets	held	for	sale	(a)

Total	premises	and	equipment
Less	accumulated	depreciation	and	
amortization

$	

163	 $	

543	

74	

276	

16	

182	

594	

73	

269	

18	

1,072	

1,136	

Premises	and	equipment,	net

$	

665	 $	

(a)	Primarily	comprised	of	land	and	buildings.

In	2021	and	2020,	FHN	recognized	$37	million	and	$12	
million,	respectively,	of	fixed	asset	impairments	and	lease	
abandonment	charges	related	to	branch	closures	which	
were	included	in	other	expense	on	the	Consolidated	
Statements	of	Income.	In	2021,	FHN	had	$6	million	of	net	
gains	related	to	the	sales	of	bank	branches	which	was	
included	in	other	income	on	the	Consolidated	Statements	
of	Income.	Similar	net	gains	in	2020	were	not	material.	

First	Horizon	as	Lessee

FHN	has	operating,	financing,	and	short-term	leases	for	
branch	locations,	corporate	offices	and	certain	equipment.	
Substantially	all	of	these	leases	are	classified	as	operating	
leases.

(407)	

(377)	

759	

The	following	table	provides	details	of	the	classification	of	
FHN's	right-of-use	assets	and	lease	liabilities	included	in	
the	Consolidated	Balance	Sheets.	

Table	8.6.2

(Dollars	in	millions)

Lease	right-of-use	assets:

Operating	lease	right-of-use	assets

Finance	lease	right-of-use	assets

Total	lease	right-of-use	assets

Lease	liabilities:

Operating	lease	liabilities

Finance	lease	liabilities

Total	lease	liabilities

RIGHT-OF-USE	ASSETS	&	LEASE	LIABILITIES

December	31,	2021

December	31,	2020

Classification

Other	assets

Other	assets

$	

$	

Other	liabilities

$	

Other	liabilities

$	

345	 $	

3	
348	 $	

382	 $	

4	
386	 $	

367	

4	

371	

407	

4	

411	

The	calculated	amount	of	the	ROU	assets	and	lease	
liabilities	in	the	table	above	are	impacted	by	the	length	of	
the	lease	term	and	the	discount	rate	used	to	present	value	
the	minimum	lease	payments.	The	following	table	details	
the	weighted	average	remaining	lease	term	and	discount	
rate	for	FHN's	operating	and	finance	leases	as	of	
December	31,	2021	and	2020.

Table	8.6.3

REMAINING	LEASE	TERMS	
&	DISCOUNT	RATES

December	31,	
2021

December	31,	
2020

Weighted	Average	Remaining	
Lease	Terms

Operating	leases

Finance	leases

12.37	years

12.49	years

10.61	years

11.45	years

Weighted	Average	Discount	Rate

Operating	leases

Finance	leases

	2.35	%

	2.85	%

	2.39	%

	3.05	%

The	following	table	provides	a	detail	of	the	components	of	
lease	expense	and	other	lease	information	for	the	years	
ended	December	31,	2021,	2020,	and	2019:

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	6—PREMISES,	EQUIPMENT,	&	LEASES

Table of Contents

Table	8.6.4

LEASE	EXPENSE	&	
OTHER	INFORMATION

(Dollars	in	millions)

2021

2020

2019

Lease	cost

Operating	lease	cost

Sublease	income

Total	lease	cost

$	

$	

Other	information

(Gain)	loss	on	right-of-
use	asset	impairment	-	
operating	leases

$	

Cash	paid	for	amounts	
included	in	the	
measurement	of	lease	
liabilities:

Operating	cash	
flows	from	
operating	leases

Right-of-use	assets	
obtained	in	exchange	
for	new	lease	
obligations:

Operating	leases

Finance	leases

48	 $	
(1)	 	
47	 $	

39	 $	

(1)	

38	 $	

25	

—	

25	

3	 $	

6	 $	

3	

53	

41	

23	

19	

—	

216	

2	

48	

1	

The	following	table	provides	a	detail	of	the	maturities	of	
FHN's	operating	and	finance	lease	liabilities	as	of	
December	31,	2021:

Table	8.6.5

arrangements	are	essentially	financing	transactions	that	
permit	lessees	to	acquire	and	use	property.		As	lessor,	the	
sum	of	all	minimum	lease	payments	over	the	lease	term	
and	the	estimated	residual	value,	less	unearned	interest	
income,	is	recorded	as	the	net	investment	in	the	lease	on	
the	commencement	date	and	is	included	in	loans	and	
leases	in	the	Consolidated	Balance	Sheets.	Interest	income	
is	accrued	as	earned	over	the	term	of	the	lease	based	on	
the	net	investment	in	leases.	Fees	incurred	to	originate	
the	lease	are	deferred	on	the	commencement	date	and	
recognized	as	an	adjustment	of	the	yield	on	the	lease.

FHN’s	portfolio	of	direct	financing	and	sales-type	leases	
contains	terms	of	1	to	23	years,	some	of	which	contain	
options	to	extend	the	lease	for	various	periods	of	time	
and/or	to	purchase	the	equipment	subject	to	the	lease	at	
various	points	in	time.	These	direct	financing	and	sales-
type	leases	typically	include	a	payment	structure	set	at	
lease	inception	and	do	not	provide	any	additional	services.	
Expenses	associated	with	the	leased	equipment,	such	as	
maintenance	and	insurance,	are	paid	by	the	lessee	directly	
to	third	parties.	The	lease	agreement	typically	contains	an	
option	for	the	purchase	of	the	leased	property	by	the	
lessee	at	the	end	of	the	lease	term	at	either	the	property’s	
residual	value	or	a	specified	price.	In	all	cases,	FHN	
expects	to	sell	or	re-lease	the	equipment	at	the	end	of	the	
lease	term.	Due	to	the	nature	and	structure	of	FHN’s	
direct	financing	and	sales-type	leases,	there	is	no	selling	
profit	or	loss	on	these	transactions.

The	components	of	the	Company’s	net	investment	in	
leases	as	of	December	31,	2021	and	2020	were	as	follows:

LEASE	LIABILITY	MATURITIES

Table	8.6.6

(Dollars	in	millions)

December	31,	2021

LEASE	NET	INVESTMENTS

(Dollars	in	millions)

December	31,	
2021

December	31,	
2020

Lease	receivable

$	

729	 $	

Unearned	income

Guaranteed	residual

Unguaranteed	residual

(135)	

97	

102	

Total	net	investment

$	

793	 $	

535	

(108)	

92	

68	

587	

Interest	income	for	direct	financing	or	sales-type	leases	
totaled	$26	million	and	$11	million	for	the	years	ended	
December	31,	2021	and	2020,	respectively.		There	was	no	
profit	or	loss	recognized	at	the	commencement	date	for	
direct	financing	or	sales-type	leases	for	the	years	ended	
December	31,	2021	and	2020.

2022

2023

2024

2025

2026

2027	and	thereafter

Total	lease	payments

Less	lease	liability	interest

Total	lease	liability

$	

$	

49	

45	

40	

39	

37	

238	

448	

(62)	

386	

FHN	had	no	aggregate	undiscounted	contractual	
obligations	for	lease	arrangements	that	have	not	
commenced	as	of	December	31,	2021.	

First	Horizon	as	Lessor

As	a	lessor,	FHN	engages	in	the	leasing	of	equipment	to	
commercial	clients	primarily	through	direct	financing	and	
sales-type	leases.	Direct	financing	and	sales-type	leases	
are	similar	to	other	forms	of	installment	lending	in	that	
lessors	generally	do	not	retain	benefits	and	risks	incidental	
to	ownership	of	the	property	subject	to	leases.	Such	

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NOTE	6—PREMISES,	EQUIPMENT,	&	LEASES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Maturities	of	the	Company's	lease	receivables	as	of	
December	31,	2021	were	as	follows:

Table	8.6.7

LEASE	RECEIVABLE	MATURITIES

(Dollars	in	millions)

December	31,	2021

$	

2022

2023

2024

2025

2026

2027	and	thereafter

Total	future	minimum	lease	payments $	

136	

122	

96	

73	

57	

245	

729	

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Table of Contents

NOTE	7—GOODWILL	&	OTHER	INTANGIBLE	ASSETS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 7—Goodwill and Other Intangible Assets 

Goodwill

On	July	1,	2020,	FHN	completed	its	merger-of-equals	
transaction	with	IBKC.	In	connection	with	the	merger,	FHN	
recorded	a	$531	million	purchase	accounting	gain,	based	
on	fair	value	estimates.

On	July	17,	2020,	FHN	completed	its	purchase	of	30	
branches	from	Truist	Bank.		In	relation	to	the	acquisition,	
FHN	recorded	$78	million	in	goodwill,	based	on	fair	value	
estimates.	See	Note	2	-	Acquisitions	and	Divestitures	for	
additional	information	regarding	these	transactions.	

FHN	performed	the	required	annual	goodwill	impairment	
test	as	of	October	1,	2021.	The	annual	impairment	test	did	
not	indicate	impairment	in	any	of	FHN’s	reporting	units	as	
of	the	testing	date.	Following	the	testing	date,	
management	evaluated	the	events	and	circumstances	that	
could	indicate	that	goodwill	might	be	impaired	and	
concluded	that	a	subsequent	interim	test	was	not	
necessary.		

As	further	discussed	in	Note	20	-	Business	Segment	
Information,	FHN	reorganized	its	management	reporting	
structure	during	2020	and,	accordingly,	its	segment	
reporting	structure	and	goodwill	reporting	units.	In	
connection	with	the	reorganization,	management	
reallocated	goodwill	to	the	new	reporting	units	using	a	
relative	fair	value	approach.	

Accounting	estimates	and	assumptions	were	made	about	
FHN’s	future	performance	and	cash	flows,	as	well	as	other	
prevailing	market	factors	(e.g.,	interest	rates,	economic	

Table	8.7.2

trends,	etc.)	when	determining	fair	value	as	part	of	the	
goodwill	impairment	test.	While	management	used	the	
best	information	available	to	estimate	future	performance	
for	each	reporting	unit,	future	adjustments	to	
management’s	projections	may	be	necessary	if	conditions	
differ	substantially	from	the	assumptions	used	in	making	
the	estimates.	

The	following	is	a	summary	of	goodwill	by	reportable	
segment	included	in	the	Consolidated	Balance	Sheets	as	of		
December	31,	2021:

Table	8.7.1

(Dollars	in	millions)

December	31,	2018

Additions

December	31,	2019

Additions

December	31,	2020

Additions

December	31,	2021

GOODWILL
Regional
Banking

Specialty
Banking

Total

$	

$	

$	

$	

802	 $	

631	 $	

1,433	

—	

—	

—	

802	 $	

631	 $	

1,433	

78	

—	

78	

880	 $	

631	 $	

1,511	

—	

—	

—	

880	 $	

631	 $	

1,511	

Other	intangible	assets

The	following	table,	which	excludes	fully	amortized	
intangibles,	presents	other	intangible	assets	included	in	
the	Consolidated	Balance	Sheets:

OTHER	INTANGIBLE	ASSETS

December	31,	2021

December	31,	2020

(Dollars	in	millions)

Gross	Carrying
Amount

Accumulated
Amortization

Net	Carrying
Value

Gross	Carrying
Amount

Accumulated
Amortization

Net	Carrying
Value

Core	deposit	intangibles

$	

371	 $	

(128)	 $	

243	 $	

371	 $	

(81)	 $	

Client	relationships

Other	(a)

Total

37	

41	

(11)	

(12)	

26	

29	

37	

41	

(8)	

(6)	

$	

449	 $	

(151)	 $	

298	 $	

449	 $	

(95)	 $	

290	

29	

35	

354	

(a) Includes	noncompete	covenants	and	purchased	credit	card	intangible	assets.	Also	includes	title	plant	intangible	assets	and	state	banking	licenses	which	

are	not	subject	to	amortization.	

Amortization	expense	was	$56	million,	$40	million,	and	
$25	million	for	the	years	ended	December	31,	2021,	2020	
and	2019,	respectively.	The	following	table	shows	the	
aggregated	amortization	expense	estimated,	as	of	
December	31,	2021,	for	the	next	five	years:	 

Table	8.7.3

ESTIMATED	AMORTIZATION	EXPENSE

(Dollars	in	millions)

2022

2023

2024

2025

2026

$	

51	

48	

44	

38	

33	

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Table of Contents

NOTE	8—MORTGAGE	BANKING	ACTIVITY

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 8—Mortgage Banking Activity 

On	July	1,	2020	as	part	of	the	IBKC	merger,	FHN	obtained	
IBKC	mortgage	banking	operations	which	includes	
origination	and	servicing	of	residential	first	lien	mortgages	
that	conform	to	standards	established	by	GSEs	that	are	
major	investors	in	U.S.	home	mortgages,	but	can	also	
consist	of	junior	lien	and	jumbo	loans	secured	by	
residential	property.	These	loans	are	primarily	sold	to	
private	companies	that	are	unaffiliated	with	the	GSEs	on	a	
servicing-released	basis.	Gains	and	losses	on	these	
mortgage	loans	are	included	in	mortgage	banking	and	title	
income	on	the	Consolidated	Statements	of	Income.	Prior	
to	the	merger,	FHN’s	mortgage	banking	operations	were	
not	significant.	At		December	31,	2021,	FHN	had	
approximately	$45	million	of	loans	that	remained	from	
pre-2009	Mortgage	Business	operations	of	legacy	First	
Horizon.		Activity	related	to	the	pre-2009	mortgage	loans	
was	primarily	limited	to	payments	and	write-offs	in	2021	
and	2020,	with	no	new	originations	or	loan	sales,	and	only	
an	insignificant	amount	of	repurchases.	These	loans	are	
excluded	from	the	disclosure	below.

The	following	table	summarizes	activity	relating	to	
residential	mortgage	loans	held	for	sale	for	the	years	
ended	December	31,	2021	and	2020:

Table	8.8.1

MORTGAGE	LOAN	ACTIVITY

(Dollars	in	millions)
Balance	at	beginning	of	period

Acquired

Originations	and	purchases

Sales,	net	of	gains

Mortgage	loans	transferred	
from	(to)	held	for	investment
Balance	at	end	of	period

2021

2020

$	

409	 $	

—	

2,836	

4	

320	

2,499	

(3,025)	 	

(2,405)	

30	

$	

250	 $	

(9)	

409	

Mortgage	Servicing	Rights

Effective	with	the	IBKC	merger,	FHN	made	an	election	to	
record	mortgage	servicing	rights	at	the	lower	of	cost	or	
market	value	and	amortize	over	the	remaining	servicing	
life	of	the	loans,	with	consideration	given	to	prepayment	
assumptions.	

Mortgage	servicing	rights	are	included	in	other	assets	on	
the	Consolidated	Balance	Sheets.	Mortgage	servicing	
rights	had	the	following	carrying	values	as	of	the	period	
indicated.

Table	8.8.2

MORTGAGE	SERVICING	RIGHTS

(Dollars	in	millions)
Mortgage	servicing	rights

(Dollars	in	millions)
Mortgage	servicing	rights

December	31,	2021

Gross
	Carrying
Amount

Accumulated
Amortization

Net	
Carrying	
Amount

$	

39	 $	

(9)	 $	

30	

December	31,	2020

Gross
	Carrying
Amount

Accumulated
Amortization

Net	
Carrying	
Amount

$	

28	 $	

(3)	 $	

25	

In	addition,	there	was	an	insignificant	amount	of	non-
mortgage	and	commercial	servicing	rights	as	of	December	
31,	2021	and	2020.	Total	mortgage	servicing	fees	included	
in	mortgage	banking	and	title	income	were	$4	million	and	
$2	million	for	the	years	ended	December	31,	2021	and	
2020,	respectively.

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NOTE	9—DEPOSITS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

 Note 9—Deposits

The	composition	of	deposits	is	presented	in	the	following	
table:

uninsured	as	of	December	31,	2021	and	2020,	
respectively.	

DEPOSITS

Scheduled	maturities	of	time	deposits	as	of	December	31,	
2021	were	as	follows:

2020

Table	8.9.2

Table	8.9.1

(Dollars	in	millions)

Savings

Time	deposits

Other	interest-bearing	deposits

Total	interest-bearing	
deposits

Noninterest-bearing	deposits

Total	deposits

2021
26,457	 $	

$	

3,500	

17,055	

47,012	

27,883	
74,895	 $	

$	

27,324	

5,070	

15,415	

47,809	

22,173	

69,982	

Time	deposits	in	denominations	that	exceed	the	FDIC	
insurance	limit	of	$250,000	at	December	31,	2021	and	
2020	were	$859	million	and	$1.4	billion,	respectively.	Of	
those	deposits,	$515	million	and	$925	million	were	

TIME	DEPOSIT	MATURITIES

(Dollars	in	millions)

2022

2023

2024

2025

2026

2027	and	after

Total

$	

3,006	

229	

115	

79	

43	

28	

$	

3,500	

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NOTE	10—SHORT-TERM	BORROWINGS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 10—Short-Term Borrowings

A	summary	of	short-term	borrowings	for	the	years	2021,	2020	and	2019	is	presented	in	the	following	table:

Table	8.10.1

(Dollars	in	millions)
2021
Average	balance
Year-end	balance
Maximum	month-end	outstanding
Average	rate	for	the	year
Average	rate	at	year-end

2020
Average	balance

Year-end	balance

Maximum	month-end	outstanding

Average	rate	for	the	year

Average	rate	at	year-end

2019
Average	balance

Year-end	balance

Maximum	month-end	outstanding

Average	rate	for	the	year

Average	rate	at	year-end

SHORT-TERM	BORROWINGS

Trading	Liabilities

Federal	Funds	
Purchased

Securities	Sold	
Under	
Agreements	to	
Repurchase

Other	Short-term	
Borrowings

$	

$	

$	

$	

$	

$	

540	
426	
685	
	1.11	%
	1.62	%

457	

353	

983	

	1.24	%

	0.77	%

503	

506	

754	

	2.48	%

	2.07	%

$	

$	

$	

949	
775	
1,037	
	0.12	%
	0.10	%

862	

845	

1,487	

	0.34	%

	0.10	%

738	

548	

1,282	

	2.08	%

	1.55	%

$	

$	

$	

1,235	
1,247	
1,615	
	0.30	%
	0.11	%

1,109	

1,187	

1,661	

	0.50	%

	0.26	%

701	

717	

772	

	2.07	%

	1.72	%

124	
102	
146	
	0.09	%
	0.08	%

626	

166	

4,061	

	0.84	%

	0.09	%

538	

2,253	

2,276	

	2.10	%

	2.14	%

Federal	funds	purchased	and	securities	sold	under	
agreements	to	repurchase	generally	have	maturities	of	
less	than	90	days.	Trading	liabilities,	which	represent	short	
positions	in	securities,	are	generally	held	for	less	than	90	
days.	Other	short-term	borrowings	have	original	

maturities	of	one	year	or	less.	On	December	31,	2021,	
fixed	income	trading	securities	with	a	fair	value	of	$33	
million	were	pledged	to	secure	other	short-term	
borrowings.

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NOTE	11—TERM	BORROWINGS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 11—Term Borrowings

Term	borrowings	include	senior	and	subordinated	
borrowings	with	original	maturities	greater	than	one	year.	
The	following	table	presents	information	pertaining	to	
term	borrowings	as	of	December	31,	2021	and	2020:

Table	8.11.1

(Dollars	in	millions)

First	Horizon	Bank:

Subordinated	notes	(a)

TERM	BORROWINGS

Maturity	date	–	May	1,	2030	-	5.75%

Other	collateralized	borrowings	-	Maturity	date	–	December	22,	2037

0.50%	on	December	31,	2021	and	0.52%	on	December	31,	2020	(b)

Other	collateralized	borrowings	-	SBA	loans	(c)

First	Horizon	Corporation:

Senior	notes

Maturity	date	–	May	26,	2023	-	3.55%	

Maturity	date	–	May	26,	2025	-	4.00%	

Junior	subordinated	debentures	(d)

Maturity	date	-	July	31,	2031	-		3.51%	on	December	31,	2020

Maturity	date	-	November	15,	2032	-		3.50%	on	December	31,	2020

Maturity	date	-	March	26,	2033	-		3.40%	on	December	31,	2020

Maturity	date	-	June	17,	2033	-	3.40%	on	December	31,	2020

Maturity	date	-	March	17,	2034	-		3.02%	on	December	31,	2020

Maturity	date	-	September	20,	2034	-		2.25%	on	December	31,	2020

Maturity	date	-	June	28,	2035	-	1.88%	on	December	31,	2021	and	1.90%	on	December	31,	2020

Maturity	date	-	December	15,	2035	-	1.57%	on	December	31,	2021	and	1.59%	on	December	31,	2020

Maturity	date	-	March	15,	2036	-	1.60%	on	December	31,	2021	and	1.62%	on	December	31,	2020

Maturity	date	-	March	15,	2036	-	1.74%	on	December	31,	2021	and	1.76%	on	December	31,	2020

Maturity	date	-	June	30,	2036	-	1.54%	on	December	31,	2021	and	1.56%	on	December	31,	2020

Maturity	date	-	July	7,	2036	-	1.67%	on	December	31,	2021	and	1.79%	on	December	31,	2020

Maturity	date	-	October	7,	2036	-	1.88%	on	December	31,	2020

Maturity	date	-	December	30,	2036	-		1.84%	on	December	31,	2020

Maturity	date	-	June	15,	2037	-	1.85%	on	December	31,	2021	and	1.87%	on	December	31,	2020

Maturity	date	-	September	6,	2037	-	1.61%	on	December	31,	2021	and	1.66%	on	December	31,	2020

Maturity	date	-	September	15,	2037	-	1.65%	on	December	31,	2020

Maturity	date	-	December	15,	2037	-		2.76%	on	December	31,	2020

Maturity	date	-	December	15,	2037	-	2.97%	on	December	31,	2020

Maturity	date	-	June	15,	2038	-		3.72%	on	December	31,	2020

Notes	payable	-	New	market	tax	credit	investments;	7	to	35	year	term,	0.93%	to	4.95%	on	December	31,	
2021;	1.27%	to	4.95%	on	December	31,	2020

FT	Real	Estate	Securities	Company,	Inc.:

Cumulative	preferred	stock	(e)

Maturity	date	–	March	31,	2031	–	9.50%

Total

2021

2020

$	

447	 $	

447	

87	

6	

448	

349	

—	

—	

—	

—	

—	

—	

3	

18	

9	

12	

27	

18	

—	

—	

52	

9	

—	

—	

—	

—	

59	

82	

15	

447	

348	

7	

9	

5	

9	

6	

8	

3	

18	

9	

12	

27	

18	

6	

10	

51	
9	

7	

10	

10	

6	

45	

46	
1,590	 $	

46	

1,670	

$	

(a) Qualifies	for	Tier	2	capital	under	the	risk-based	capital	guidelines	for	First	Horizon	Bank	as	well	as	First	Horizon	Corporation	up	to	certain	limits	for	

minority	interest	capital	instruments.

(b) Secured	by	trust	preferred	loans.

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NOTE	11—TERM	BORROWINGS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(c) Collateralized	borrowings	associated	with	SBA	loan	sales	that	did	not	meet	sales	criteria.	The	loans	have	remaining	terms	of	4	to	25	years.	These	

borrowings	had	a	weighted	average	interest	rate	of	4.10%	and	3.90%	on	December	31,	2021	and	2020,	respectively.

(d) Acquired	in	conjunction	with	the	acquisitions	of	CBF	and	merger	with	IBKC.	The	legacy	IBKC	junior	subordinated	debentures	were	early	redeemed	in	

2021.	A	portion	qualifies	for	Tier	2	capital	under	the	risk-based	capital	guidelines.	

(e) Qualifies	for	Tier	2	capital	under	the	risk-based	capital	guidelines	for	both	First	Horizon	Bank	and	First	Horizon	Corporation	up	to	certain	limits	for	

minority	interest	capital	instruments.

Annual	principal	repayment	requirements	as	of	
December	31,	2021	are	as	follows:

Table	8.11.2

ANNUAL	PRINCIPAL	REPAYMENT	SCHEDULE

(Dollars	in	millions)

2022

2023

2024

2025

2026	and	after

$	

—	

450	

6	

350	

807	

In	conjunction	with	its	acquisitions,	FHN	obtained	junior	
subordinated	debentures,	each	of	which	is	held	by	a	
wholly-owned	trust	that	has	issued	trust	preferred	
securities	to	external	investors	and	loaned	the	funds	to	
FHN	as	junior	subordinated	debt.	The	book	value	for	each	

issuance	represents	the	purchase	accounting	fair	value	as	
of	the	closing	date	less	accumulated	amortization	of	the	
associated	discount,	as	applicable.	Through	various	
contractual	arrangements,	FHN	assumed	a	full	and	
unconditional	guarantee	for	each	trust’s	obligations	with	
respect	to	the	securities.	While	the	maturity	dates	are	
typically	30	years	from	the	original	issuance	date,	FHN	has	
the	option	to	redeem	each	of	the	junior	subordinated	
debentures	at	par	on	any	future	interest	payment	date,	
which	would	trigger	redemption	of	the	related	trust	
preferred	securities.		During	2021,	FHN	redeemed	
$94	million	of	legacy	IBKC	junior	subordinated	debt	
underlying	multiple	issuances	of	trust	preferred	securities.	
The	redemption	resulted	in	a	loss	on	debt	extinguishment	
of	$26	million.	A	portion	of	FHN's	remaining	junior	
subordinated	notes	qualifies	as	Tier	2	capital	under	the	
risk-based	capital	guidelines.

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NOTE	12—PREFERRED	STOCK

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 12—Preferred Stock

FHN	Preferred	Stock

The	following	table	presents	a	summary	of	FHN's	non-cumulative	perpetual	preferred	stock:

Table	8.12.1

(Dollars	in	millions)

FHN	PREFERRED	STOCK

December	31,

2021

2020

Issuance	
Date

Earliest	
Redemption	
Date	(a)	

Annual	
Dividend	
Rate

Dividend	
Payments

Shares	
Outstanding

Liquidation	
Amount

Carrying	
Amount

Carrying	
Amount

Series	A	

Series	B	

Series	C	

Series	D	

Series	E	
Series	F

1/31/2013

4/10/2018

	6.200	%

Quarterly

—	 $	

7/2/2020

8/1/2025

	6.625	% (b)

Semi-annually

7/2/2020

5/1/2026

	6.600	% (c)

Quarterly

7/2/2020

5/1/2024

	6.100	% (d)

Semi-annually

5/28/2020

10/10/2025

5/3/2021

7/10/2026

	6.500	%
	4.700	%

Quarterly

Quarterly

8,000	

5,750	

10,000	

1,500	
1,500	
26,750	 $	

—	 $	
80	

58	

100	

150	
150	
538	 $	

—	 $	
77	

59	

94	

145	
145	
520	 $	

95	

77	

59	

94	

145	
—	
470	

(a)	 Denotes	earliest	optional	redemption	date.	Earlier	redemption	is	possible,	at	FHN's	election,	if	certain	regulatory	capital	events	occur.
(b)	 Fixed	dividend	rate	will	reset	on	August	1,	2025	to	three-month	LIBOR	plus	4.262%
(c)	 Fixed	dividend	rate	will	reset	on	May	1,	2026	to	three-month	LIBOR	plus	4.920%
(d)	 Fixed	dividend	rate	will	reset	on	May	1,	2024	to	three-month	LIBOR	plus	3.859%

Cumulative	Preferred	Stock,	Class	B	(Class	B	Preferred	
Shares),	with	a	liquidation	preference	of	$1	million	per	
share;	of	those	shares,	47	were	issued	to	nonaffiliates.	
FTRESC	is	a	real	estate	investment	trust	established	for	
the	purpose	of	acquiring,	holding,	and	managing	real	
estate	mortgage	assets.	Dividends	on	the	Class	B	Preferred	
Shares	are	cumulative	and	are	payable	semi-annually.	At	
December	31,	2021,	the	Class	B	Preferred	Shares	partially	
qualified	as	Tier	2	regulatory	capital.	For	all	periods	
presented,	these	securities	are	presented	in	the	
Consolidated	Balance	Sheets	as	Term	borrowings.	

The	Class	B	Preferred	Shares	are	mandatorily	redeemable	
on	March	31,	2031,	and	redeemable	at	the	discretion	of	
FTRESC	in	the	event	that	the	Class	B	Preferred	Shares	
cannot	be	accounted	for	as	Tier	2	regulatory	capital	or	
there	is	more	than	an	insubstantial	risk	that	dividends	paid	
with	respect	to	the	Class	B	Preferred	Shares	will	not	be	
fully	deductible	for	tax	purposes.	

During	2021,	FHN	issued	$150	million	of	4.70%	Series	F	
Non-Cumulative	Perpetual	Preferred	Stock	(the	Series	F	
Preferred	Stock).	The	Series	F	Preferred	Stock	is	
redeemable	at	FHN's	option,	in	whole	or	in	part,	on	or	
after	July	10,	2026.	Earlier	redemption	is	possible,	at	FHN's	
election,	if	certain	regulatory	capital	events	occur.	The	
$145	million	carrying	value	of	the	Series	F	Preferred	Stock	
currently	qualifies	as	Tier	1	Capital.

During	2021,	FHN	redeemed	all	outstanding	shares	of	
Series	A	Preferred	Stock.	The	difference	between	the	
$100	million	liquidation	preference	and	the	carrying	value	
of	the	Series	A	Preferred	Stock	resulted	in	a	$5	million	
deemed	dividend	that	was	included	in	EPS	for	the	year	
ended	December	31,	2021.

Subsidiary	Preferred	Stock

First	Horizon	Bank	has	issued	300,000	shares	of	Class	A	
Non-Cumulative	Perpetual	Preferred	Stock	(Class	A	
Preferred	Stock)	with	a	liquidation	preference	of	$1,000	
per	share.	Dividends	on	the	Class	A	Preferred	Stock,	if	
declared,	accrue	and	are	payable	each	quarter,	in	arrears,	
at	a	floating	rate	equal	to	the	greater	of	the	three	month	
LIBOR	plus	0.85%	or	3.75%	per	annum.	These	securities	
qualify	fully	as	Tier	1	capital	for	both	First	Horizon	Bank	
and	FHN.	On	December	31,	2021	and	2020,	$295	million	
of	Class	A	Preferred	Stock	was	recognized	as	
noncontrolling	interest	on	the	Consolidated	Balance	
Sheets.

FT	Real	Estate	Securities	Company,	Inc.	(FTRESC),	an	
indirect	subsidiary	of	FHN,	has	issued	50	shares	of	9.50%	

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NOTE	13—REGULATORY	CAPITAL	&	RESTRICTIONS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 13—Regulatory Capital and Restrictions

Regulatory	Capital

FHN	is	subject	to	various	regulatory	capital	requirements	
administered	by	the	federal	banking	agencies.	Failure	to	
meet	minimum	capital	requirements	can	initiate	certain	
mandatory,	and	possibly	additional	discretionary	actions	
by	regulators	that,	if	undertaken,	could	have	a	direct	
material	effect	on	FHN’s	financial	statements.	Under	
capital	adequacy	guidelines	and	the	regulatory	framework	
for	prompt	corrective	action,	FHN	must	meet	specific	
capital	guidelines	that	involve	quantitative	measures	of	
assets,	liabilities,	and	certain	off-balance	sheet	items	
calculated	pursuant	to	regulatory	directives.	Capital	
amounts	and	classification	are	also	subject	to	qualitative	
judgment	by	the	regulators	such	as	capital	components,	
asset	risk	weightings,	and	other	factors.	

Management	believes	that,	as	of	December	31,	2021,	FHN	
and	First	Horizon	Bank	met	all	capital	adequacy	
requirements	to	which	they	were	subject.	As	of	
December	31,	2021,	First	Horizon	Bank	was	classified	as	

well-capitalized	under	the	regulatory	framework	for	
prompt	corrective	action.	To	be	categorized	as	well-
capitalized,	an	institution	must	maintain	minimum	Total	
Risk-Based,	Tier	1	Risk-Based,	Common	Equity	Tier	1	and	
Tier	1	Leverage	ratios	as	set	forth	in	the	following	table.	
Management	believes	that	no	events	or	changes	have	
occurred	subsequent	to	year-end	that	would	change	this	
designation.	

Quantitative	measures	established	by	regulation	to	ensure	
capital	adequacy	require	FHN	to	maintain	minimum	ratios	
as	set	forth	in	the	following	table.	FHN	and	First	Horizon	
Bank	are	also	subject	to	a	2.5%	capital	conservation	buffer	
which	is	an	amount	above	the	minimum	levels	designed	to	
ensure	that	banks	remain	well-capitalized,	even	in	adverse	
economic	scenarios.

The	actual	capital	amounts	and	ratios	of	FHN	and	First	
Horizon	Bank	are	presented	in	the	following	table.

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Table	8.13.1

(Dollars	in	millions)

On	December	31,	2021

Actual:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	13—REGULATORY	CAPITAL	&	RESTRICTIONS

CAPITAL	AMOUNTS	&	RATIOS

First	Horizon	Corporation

First	Horizon	Bank

Amount

Ratio

Amount

Ratio

Minimum	Requirement	for	Capital	Adequacy	Purposes:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

Minimum	Requirement	to	be	Well	Capitalized	Under	
Prompt	Corrective	Action	Provisions:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

On	December	31,	2020

Actual:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

Minimum	Requirement	for	Capital	Adequacy	Purposes:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

Minimum	Requirement	to	be	Well	Capitalized	Under	
Prompt	Corrective	Action	Provisions:

Total	Capital

Tier	1	Capital

Common	Equity	Tier	1

Leverage

$	

$	

7,918	

7,088	

6,367	

7,088	

5,135	

3,851	

2,888	
3,507	

7,935	

6,782	

6,110	

6,782	

5,051	

3,788	

2,841	

3,294	

	12.34	% $	

	11.04	

	9.92	

	8.08	

	8.00	

	6.00	

	4.50	
	4.00	

	12.57	% $	

	10.74	

	9.68	

	8.24	

	8.00	

	6.00	

	4.50	

	4.00	

7,893	

7,133	

6,838	

7,133	

5,088	

3,816	

2,862	
3,478	

6,360	

5,088	

4,134	

4,348	

7,827	

6,832	

6,537	

6,832	

5,001	

3,751	

2,813	

3,268	

6,251	

5,001	

4,063	

4,085	

	12.41	%

	11.22	

	10.75	

	8.20	

	8.00	

	6.00	

	4.50	
	4.00	

	10.00	

	8.00	

	6.50	

	5.00	

	12.52	

	10.93	

	10.46	

	8.36	

	8.00	

	6.00	

	4.50	

	4.00	

	10.00	

	8.00	

	6.50	

	5.00	

Restrictions	on	cash	and	due	from	banks

Restrictions	on	dividends

Under	the	Federal	Reserve	Act	and	Regulation	D,	First	
Horizon	Bank	is	required	to	maintain	a	certain	amount	of	
cash	reserves.	However,	as	a	result	of	the	COVID-19	
pandemic,	the	Fed	announced	it	has	reduced	its	reserve	
requirement	to	zero,	and	as	a	result,	on	December	31,	
2021	and	2020,	First	Horizon	Bank	was	not	required	to	
maintain	cash	reserves	after	the	consideration	of	$464	
million	and	$397	million	in	average	vault	cash	respectively.	

Cash	dividends	are	paid	by	FHN	from	its	assets,	which	are	
mainly	provided	by	dividends	from	its	subsidiaries.	Certain	
regulatory	restrictions	exist	regarding	the	ability	of	First	
Horizon	Bank	to	transfer	funds	to	FHN	in	the	form	of	cash,	
dividends,	loans,	or	advances.	As	of	December	31,	2021,	
First	Horizon	Bank	had	undivided	profits	of	$2.2	billion,	of	
which	a	limited	amount	was	available	for	distribution	to	
FHN	as	dividends	without	prior	regulatory	approval.		At	
any	given	time,	the	pertinent	portions	of	those	regulatory	

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NOTE	13—REGULATORY	CAPITAL	&	RESTRICTIONS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

restrictions	allow	First	Horizon	Bank	to	declare	preferred	
or	common	dividends	without	prior	regulatory	approval	in	
an	amount	equal	to	First	Horizon	Bank's	retained	net	
income	for	the	two	most	recent	completed	years	plus	the	
current	year-to-date	period.	For	any	period,	First	Horizon	
Bank’s	"retained	net	income"	generally	is	equal	to	First	
Horizon	Bank’s	regulatory	net	income	reduced	by	the	
preferred	and	common	dividends	declared	by	First	
Horizon	Bank.	Applying	the	dividend	restrictions	imposed	
under	applicable	federal	and	state	rules,	First	Horizon	
Bank’s	total	amount	available	for	dividends	was	$1.1	
billion	at	January	1,	2022.	First	Horizon	Bank	declared	and	
paid	common	dividends	to	the	parent	company	in	the	
amount	of	$770	million	in	2021	and	$180	million	in	2020.	
During	2021	and	2020,	First	Horizon	Bank	declared	and	
paid	dividends	on	its	preferred	stock	according	to	the	
payment	terms	of	its	issuances	as	noted	in	Note	12	-	
Preferred	Stock.

The	payment	of	cash	dividends	by	FHN	and	First	Horizon	
Bank	may	also	be	affected	or	limited	by	other	factors,	such	
as	the	requirement	to	maintain	adequate	capital	above	
regulatory	guidelines.	Furthermore,	the	Federal	Reserve	
generally	requires	insured	banks	and	bank	holding	
companies	to	pay	dividends	only	out	of	current	operating	
earnings.	

Restrictions	on	intercompany	transactions

Under	current	Federal	banking	laws,	First	Horizon	Bank	
may	not	enter	into	covered	transactions	with	any	affiliate	

including	the	parent	company	and	certain	financial	
subsidiaries	in	excess	of	10%	of	the	bank’s	capital	stock	
and	surplus,	as	defined,	or	$812	million,	on	December	31,	
2021.	Covered	transactions	include	a	loan	or	extension	of	
credit	to	an	affiliate,	a	purchase	of	or	an	investment	in	
securities	issued	by	an	affiliate,	and	the	acceptance	of	
securities	issued	by	the	affiliate	as	collateral	for	any	loan	
or	extension	of	credit.	The	equity	investment,	including	
retained	earnings,	in	certain	of	a	bank’s	financial	
subsidiaries	is	also	treated	as	a	covered	transaction.	On	
December	31,	2021,	the	parent	company	had	covered	
transactions	of	less	than	$1	million	from	First	Horizon	
Bank,	and	840	Denning	LLC,	a	parent	company	subsidiary,	
had	a	covered	transaction	of	$2	million.	Two	of	the	bank’s	
financial	subsidiaries,	FHN	Financial	Securities	Corp.	and	
First	Horizon	Advisors,	Inc.,	had	covered	transactions	from	
First	Horizon	Bank	totaling	$400	million	and	$51	million,	
respectively.	In	addition,	the	aggregate	amount	of	covered	
transactions	with	all	affiliates,	as	defined,	is	limited	to	20%	
of	the	bank’s	capital	stock	and	surplus,	as	defined,	or	$1.6	
billion,	on	December	31,	2021.	First	Horizon	Bank’s	total	
covered	transactions	with	all	affiliates	including	the	parent	
company	on	December	31,	2021	were	$453	million.

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NOTE	14—COMPONENTS	OF	OTHER	COMPREHENSIVE	INCOME	(LOSS)

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 14—Components of Other Comprehensive Income (Loss)

The	following	table	provides	the	changes	in	accumulated	other	comprehensive	income	(loss)	by	component,	net	of	tax,	for	the	
years	ended	December	31,	2021,	2020,	and	2019:

Table	8.14.1

ACCUMULATED	OTHER	COMPREHENSIVE	INCOME	(LOSS)

(Dollars	in	millions)
Balance	as	of	December	31,	2018

Net	unrealized	gains	(losses)

Amounts	reclassified	from	AOCI

Other	comprehensive	income	(loss)

Balance	as	of	December	31,	2019

Net	unrealized	gains	(losses)

Amounts	reclassified	from	AOCI

Other	comprehensive	income	(loss)

Balance	as	of	December	31,	2020
Net	unrealized	gains	(losses)

Amounts	reclassified	from	AOCI

Other	comprehensive	income	(loss)

Balance	as	of	December	31,	2021

Securities	AFS

Cash	Flow
Hedges

Pension	and
Post-retirement
Plans

Total

$	

(76)	 $	

(12)	 $	

(288)	 $	

107	

—	

107	

31	

74	

3	

77	

108	
(144)	

—	

(144)	

$	

(36)	 $	

11	

4	

15	

3	

15	

(6)	

9	

12	
(3)	

(7)	

(10)	

2	 $	

8	

7	

15	

(273)	

3	

10	

13	

(260)	
(2)	

8	

6	

(254)	 $	

(376)	

126	

11	

137	

(239)	

92	

7	

99	

(140)	
(149)	

1	

(148)	

(288)	

Reclassifications	from	AOCI,	and	related	tax	effects,	were	as	follows:

Table	8.14.2

(Dollars	in	millions)

Details	about	AOCI
Securities	AFS:

RECLASSIFICATIONS	FROM	AOCI

2021

2020

2019

Affected	line	item	in	the	statement	
where	net	income	is	presented

Realized	(gains)	losses	on	securities	AFS

$	

Tax	expense	(benefit)

Cash	flow	hedges:

Realized	(gains)	losses	on	cash	flow	hedges

Tax	expense	(benefit)

Pension	and	Postretirement	Plans:

Amortization	of	prior	service	cost	and	net	actuarial	
(gain)	loss
Tax	expense	(benefit)

—	 $	
—	

—	

(9)	

2	

(7)	

10	

(2)	

Total	reclassification	from	AOCI

8	
1	 $	

$	

4	 $	

—	 Securities	gains	(losses),	net

(1)	

3	

(8)	

2	

(6)	

13	

(3)	

10	

7	 $	

Income	tax	expense

—	

—	

5	

Interest	and	fees	on	loans	and	leases

(1)	

Income	tax	expense

4	

10	 Other	expense

(3)	

Income	tax	expense

7	

11	

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NOTE	15—INCOME	TAXES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 15—Income Taxes

The	aggregate	amount	of	income	taxes	included	in	the	Consolidated	Statements	of	Income	and	the	Consolidated	Statements	
of	Changes	in	Equity	for	the	years	ended	December	31,	were	as	follows:

Table	8.15.1

(Dollars	in	millions)

Consolidated	Statements	of	Income:
Income	tax	expense

Consolidated	Statements	of	Changes	in	Equity:
Income	tax	expense	(benefit)	related	to:

INCOME	TAX	EXPENSE

2021

2020

2019

$	

274	 $	

76	 $	

134	

Net	unrealized	gains	on	pension	and	other	postretirement	plans

Net	unrealized	gains	(losses)	on	securities	available	for	sale

Net	unrealized	gains	(losses)	on	cash	flow	hedges

Total

2	

(46)	

(3)	
227	 $	

3	

25	

3	

107	 $	

$	

The	components	of	income	tax	expense	(benefit)	for	the	years	ended	December	31,	were	as	follows:

Table	8.15.2

(Dollars	in	millions)

Current:

Federal

State

Deferred:

Federal

State

Total

INCOME	TAX	EXPENSE	COMPONENTS

2021

2020

2019

$	

235	 $	

39	

(1)	

1	
274	 $	

$	

80	 $	

14	

(15)	

(3)	

76	 $	

5	

35	

5	

179	

106	

14	

5	

9	

134	

A	reconciliation	of	expected	income	tax	expense	(benefit)	at	the	federal	statutory	rate	of	21%	for	2021,	2020,	and	2019,	
respectively	to	the	total	income	tax	expense	follows:

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	15—INCOME	TAXES

RECONCILIATION	FROM	STATUTORY	RATES

As	of	December	31,	2021,	FHN	had	net	deferred	tax	asset	balances	related	to	federal	and	state	income	tax	carryforwards	of	
$38	million	and	$2	million,	respectively,	which	will	expire	at	various	dates	as	follows:

TAX	CARRYFORWARD	DTA	EXPIRATION	DATES

Table of Contents

Table	8.15.3

(Dollars	in	millions)

Federal	income	tax	rate

Tax	computed	at	statutory	rate

Increase	(decrease)	resulting	from:

State	income	taxes,	net	of	federal	income	tax	benefit

Bank-owned	life	insurance

401(k)	–	employee	stock	ownership	plan

Tax-exempt	interest

Non-deductible	expenses

LIHTC	credits	and	benefits,	net	of	amortization	

Other	tax	credits

Other	changes	in	unrecognized	tax	benefits
Purchase	accounting	gain

Other

Total

Table	8.15.4

(Dollars	in	millions)

Losses	-	federal

Net	operating	losses	-	states

A	DTA	or	DTL	is	recognized	for	the	tax	consequences	of	
temporary	differences	between	the	financial	statement	
carrying	amounts	and	the	tax	bases	of	existing	assets	and	
liabilities.	The	tax	consequence	is	calculated	by	applying	
enacted	statutory	tax	rates,	applicable	to	future	years,	to	
these	temporary	differences.	In	order	to	support	the	
recognition	of	the	DTA,	FHN’s	management	must	believe	
that	the	realization	of	the	DTA	is	more	likely	than	not.	FHN	
evaluates	the	likelihood	of	realization	of	the	DTA	based	on	
both	positive	and	negative	evidence	available	at	the	time,	
including	(as	appropriate)	scheduled	reversals	of	DTLs,	
projected	future	taxable	income,	tax	planning	strategies,	
and	recent	financial	performance.	Realization	is	
dependent	on	generating	sufficient	taxable	income	prior	
to	the	expiration	of	the	carryforwards	attributable	to	the	
DTA.	In	projecting	future	taxable	income,	FHN	
incorporates	assumptions	including	the	estimated	amount	
of	future	state	and	federal	pretax	operating	income,	the	
reversal	of	temporary	differences,	and	the	

2021

2020

2019

$	

	21	%

270	

$	

	21	%

196	

$	

	21	%

123	

32	

(7)	

(1)	

(10)	

8	

(14)	

(4)	

4	
—	

(4)	

$	

274	

$	

9	

(6)	

(1)	

(8)	

13	

(9)	

(5)	

(9)	
(112)	

8	

76	

15	

(5)	

(1)	

(6)	

11	

(4)	

—	

4	
—	

(3)	

$	

134	

Expiration	
Dates

Net	Deferred	Tax
Asset	Balance

2026	-	2035

$	

2027	-	2040

38	

2	

implementation	of	feasible	and	prudent	tax	planning	
strategies.	These	assumptions	require	significant	
judgment	about	the	forecasts	of	future	taxable	income	
and	are	consistent	with	the	plans	and	estimates	used	to	
manage	the	underlying	business.

As	of	December	31,	2021,	FHN's	net	DTA	was	$52	million	
compared	to	less	than	$1	million	at	December	31,	2020.	
At	December	31,	2021,	FHN's	gross	DTA	(net	of	a	valuation	
allowance)	and	gross	DTL	were	$448	million	and	$396	
million,	respectively.	Although	realization	is	not	assured,	
FHN	believes	that	it	meets	the	more-likely-than-not	
requirement	with	respect	to	the	net	DTA	after	valuation	
allowance.

Temporary	differences	which	gave	rise	to	deferred	tax	
assets	and	deferred	tax	liabilities	on	December	31,	2021	
and	2020	were	as	follows:

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	15—INCOME	TAXES

COMPONENTS	OF	DTAs	&	DTLs

Table of Contents

Table	8.15.5

(Dollars	in	millions)

Deferred	tax	assets:
Loss	reserves

Employee	benefits

Accrued	expenses

Depreciation	and	amortization

Lease	liability

Federal	loss	carryforwards

State	loss	carryforwards

Investment	in	debt	securities	(ASC	320)	(a)

Other

Gross	deferred	tax	assets

Deferred	tax	liabilities:
Depreciation	and	amortization

Investment	in	debt	securities	(ASC	320)	(a)

Equity	investments

Other	intangible	assets

Prepaid	expenses

ROU	lease	asset

Leasing

Other

Gross	deferred	tax	liabilities

Net	deferred	tax	assets

2021

2020

$	

161	 $	

83	

16	

13	

94	

38	

2	

12	

29	

448	

$	

—	 $	
—	

4	

86	

18	

85	

198	

5	

396	

$	

52	 $	

205	

86	

7	

—	

100	

44	

9	

—	

20	

471	

83	

35	

11	

93	

15	

89	

135	

10	

471	

—	

(a)	 Tax	effects	of	unrealized	gains	and	losses	are	tracked	on	a	security-by-security	basis.

The	total	unrecognized	tax	benefits	at	December	31,	2021	
and	2020,	was	$92	million	and	$70	million,	respectively.	
To	the	extent	such	unrecognized	tax	benefits	as	of	
December	31,	2021	are	subsequently	recognized,	$42	
million	of	tax	benefits	could	impact	tax	expense	and	FHN’s	
effective	tax	rate	in	future	periods.

FHN	is	currently	under	audit	in	several	jurisdictions.	It	is	
reasonably	possible	that	the	unrecognized	tax	benefits	
related	to	federal	and	state	exposures	could	decrease	by	
$58	million	during	2022	if	audits	are	completed	and	
settled	and	if	the	applicable	statutes	of	limitations	expire	
as	scheduled.

FHN	recognizes	interest	accrued	and	penalties	related	to	
unrecognized	tax	benefits	within	income	tax	expense.	FHN	
had	approximately	$14	million	and	$11	million	accrued	for	
the	payment	of	interest	as	of	December	31,	2021	and	
2020,	respectively.	The	total	amount	of	interest	and	
penalties	recognized	in	the	Consolidated	Statements	of	
Income	during	2021	and	2020	was	an	expense	of	$3	
million	and	$8	million,	respectively.

The	rollforward	of	unrecognized	tax	benefits	is	shown	in	
the	following	table:

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Table	8.15.6

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	15—INCOME	TAXES

ROLLFORWARD	OF	UNRECOGNIZED	TAX	BENEFITS

(Dollars	in	millions)

Balance	at	December	31,	2019

Increases	related	to	prior	year	tax	positions

Increases	related	to	current	year	tax	positions

Settlements

Lapse	of	statutes

Balance	at	December	31,	2020

Increases	related	to	prior	year	tax	positions

Increases	related	to	current	year	tax	positions

Lapse	of	statutes

Balance	at	December	31,	2021

$	

$	

$	

24	

56	

1	

(10)	

(1)	

70	

24	

1	

(3)	

92	

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NOTE	16—EARNINGS	PER	SHARE

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 16—Earnings Per Share 

The	following	table	provides	reconciliations	of	net	income	to	net	income	available	to	common	shareholders	and	the	
difference	between	average	basic	common	shares	outstanding	and	average	diluted	common	shares	outstanding:

Table	8.16.1

NET	INCOME	&	COMMON	SHARE	RECONCILIATIONS 

(Dollars	in	millions,	except	per	share	data;	shares	in	thousands)
Net	income
Net	income	attributable	to	noncontrolling	interest

Net	income	attributable	to	controlling	interest

Preferred	stock	dividends

Net	income	available	to	common	shareholders

Weighted	average	common	shares	outstanding—basic

Effect	of	dilutive	securities

Weighted	average	common	shares	outstanding—diluted

Basic	earnings	per	common	share	

Diluted	earnings	per	common	share	

The	following	table	presents	outstanding	options	and	
other	equity	awards	that	were	excluded	from	the	
calculation	of	diluted	earnings	per	share	because	they	
were	either	anti-dilutive	(the	exercise	price	was	higher	

Table	8.16.2

2021

2020

2019

1,010	

$	

857	

$	

11	

999	

37	

12	

845	

23	

962	

$	

822	

$	

452	

11	

441	

6	

435	

546,354	

4,887	

551,241	

432,125	

1,592	

433,717	

1.76	

1.74	

$	
$	

1.90	
1.89	

$	
$	

313,637	

2,020	

315,657	

1.39	
1.38	

$	

$	

$	

$	

than	the	weighted-average	market	price	for	the	period)	or	
the	performance	conditions	have	not	been	met:

ANTI-DILUTIVE	EQUITY	AWARDS 

(Shares	in	thousands)
Stock	options	excluded	from	the	calculation	of	diluted	EPS

2021

2020

2019

1,366	

4,595	

Weighted	average	exercise	price	of	stock	options	excluded	from	the	
calculation	of	diluted	EPS
Other	equity	awards	excluded	from	the	calculation	of	diluted	EPS

$	

20.44	

$	

1,531	

17.47	

$	

3,639	

2,359	

21.12	

2,224	

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NOTE	17—CONTINGENCIES	&	OTHER	DISCLOSURES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 17—Contingencies and Other Disclosures

Contingencies	

Contingent	Liabilities	Overview

Contingent	liabilities	arise	in	the	ordinary	course	of	
business.	Often	they	are	related	to	lawsuits,	arbitration,	
mediation,	and	other	forms	of	litigation.	Various	litigation	
matters	are	threatened	or	pending	against	FHN	and	its	
subsidiaries.	Also,	FHN	at	times	receives	requests	for	
information,	subpoenas,	or	other	inquiries	from	federal,	
state,	and	local	regulators,	from	other	government	
authorities,	and	from	other	parties	concerning	various	
matters	relating	to	FHN’s	current	or	former	businesses.	
Certain	matters	of	that	sort	are	pending	at	most	times,	
and	FHN	generally	cooperates	when	those	matters	arise.	
Pending	and	threatened	litigation	matters	sometimes	are	
settled	by	the	parties,	and	sometimes	pending	matters	are	
resolved	in	court	or	before	an	arbitrator,	or	are	
withdrawn.	Regardless	of	the	manner	of	resolution,	
frequently	the	most	significant	changes	in	status	of	a	
matter	occur	over	a	short	time	period,	often	following	a	
lengthy	period	of	little	substantive	activity.	In	view	of	the	
inherent	difficulty	of	predicting	the	outcome	of	these	
matters,	particularly	where	the	claimants	seek	very	large	
or	indeterminate	damages,	or	where	the	cases	present	
novel	legal	theories	or	involve	a	large	number	of	parties,	
or	where	claims	or	other	actions	may	be	possible	but	have	
not	been	brought,	FHN	cannot	reasonably	determine	what	
the	eventual	outcome	of	the	matters	will	be,	what	the	
timing	of	the	ultimate	resolution	of	these	matters	may	be,	
or	what	the	eventual	loss	or	impact	related	to	each	matter	
may	be.	FHN	establishes	a	loss	contingency	liability	for	a	
litigation	matter	when	loss	is	both	probable	and	
reasonably	estimable	as	prescribed	by	applicable	financial	
accounting	guidance.	If	loss	for	a	matter	is	probable	and	a	
range	of	possible	loss	outcomes	is	the	best	estimate	
available,	accounting	guidance	requires	a	liability	to	be	
established	at	the	low	end	of	the	range.

Based	on	current	knowledge,	and	after	consultation	with	
counsel,	management	is	of	the	opinion	that	loss	
contingencies	related	to	threatened	or	pending	litigation	
matters	should	not	have	a	material	adverse	effect	on	the	
consolidated	financial	condition	of	FHN,	but	may	be	
material	to	FHN’s	operating	results	for	any	particular	
reporting	period	depending,	in	part,	on	the	results	from	
that	period.

Material	Loss	Contingency	Matters	

Summary

As	used	in	this	Note,	except	for	matters	that	are	reported	
as	having	been	substantially	settled	or	otherwise	
substantially	resolved,	FHN's	“material	loss	contingency	
matters”	generally	fall	into	at	least	one	of	the	following	
categories:	(i)	FHN	has	determined	material	loss	to	be	
probable	and	has	established	a	material	loss	liability	in	
accordance	with	applicable	financial	accounting	guidance;	

(ii)	FHN	has	determined	material	loss	to	be	probable	but	is	
not	reasonably	able	to	estimate	an	amount	or	range	of	
material	loss	liability;	or	(iii)	FHN	has	determined	that	
material	loss	is	not	probable	but	is	reasonably	possible,	
and	the	amount	or	range	of	that	reasonably	possible	
material	loss	is	estimable.	As	defined	in	applicable	
accounting	guidance,	loss	is	reasonably	possible	if	there	is	
more	than	a	remote	chance	of	a	material	loss	outcome	for	
FHN.	FHN	provides	contingencies	note	disclosures	for	
certain	pending	or	threatened	litigation	matters	each	
quarter,	including	all	matters	mentioned	in	categories	(i)	
or	(ii)	and,	occasionally,	certain	matters	mentioned	in	
category	(iii).	In	addition,	in	this	Note,	certain	other	
matters,	or	groups	of	matters,	are	discussed	relating	to	
FHN’s	pre-2009	mortgage	origination	and	servicing	
businesses.	In	all	litigation	matters	discussed	in	this	Note,	
unless	settled	or	otherwise	resolved,	FHN	believes	it	has	
meritorious	defenses	and	intends	to	pursue	those	
defenses	vigorously.

FHN	reassesses	the	liability	for	litigation	matters	each	
quarter	as	the	matters	progress.	At	December	31,	2021,	
the	aggregate	amount	of	liabilities	established	for	all	such	
loss	contingency	matters	was	$2	million.	These	liabilities	
are	separate	from	those	discussed	under	the	heading	
Mortgage	Loan	Repurchase	and	Foreclosure	Liability	
below.

In	each	material	loss	contingency	matter,	except	as	
otherwise	noted,	there	is	more	than	a	remote	chance	that	
any	of	the	following	outcomes	will	occur:	the	plaintiff	will	
substantially	prevail;	the	defense	will	substantially	prevail;	
the	plaintiff	will	prevail	in	part;	or	the	matter	will	be	
settled	by	the	parties.	At	December	31,	2021,	FHN	
estimates	that	for	all	material	loss	contingency	matters,	
estimable		reasonably	possible	losses	in	future	periods	in	
excess	of	currently	established	liabilities	could	aggregate	
in	a	range	from	zero	to	less	than	$1	million.

As	a	result	of	the	general	uncertainties	discussed	above	
and	the	specific	uncertainties	discussed	for	each	matter	
mentioned	below,	it	is	possible	that	the	ultimate	future	
loss	experienced	by	FHN	for	any	particular	matter	may	
materially	exceed	the	amount,	if	any,	of	currently	
established	liability	for	that	matter.	

Material	Matters

At	December	31,	2021,	no	pending	or	known	threatened	
matters	were	material	loss	contingency	matters,	as	
described	above.

Exposures	from	pre-2009	Mortgage	Business

FHN	is	contending	with	indemnification	claims	related	to	
"other	whole	loans	sold,"	which	were	mortgage	loans	
originated	by	FHN	before	2009	and	sold	outside	of	a	
securitization	organized	by	FHN.	These	claims	generally	
assert	that	FHN-originated	loans	contributed	to	losses	in	

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NOTE	17—CONTINGENCIES	&	OTHER	DISCLOSURES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

exposures),	estimated	future	inflows,	and	estimated	loss	
content	related	to	certain	known	claims	not	currently	
included	in	the	active	pipeline.	FHN	compares	the	
estimated	probable	incurred	losses	determined	under	the	
applicable	loss	estimation	approaches	for	the	respective	
periods	with	current	reserve	levels.	Changes	in	the	
estimated	required	liability	levels	are	recorded	as	
necessary	through	the	repurchase	and	foreclosure	
provision.

Based	on	currently	available	information	and	experience	
to	date,	FHN	has	evaluated	its	loan	repurchase,	make-
whole,	foreclosure,	and	certain	related	exposures	and	has	
accrued	for	losses	of	$17	million	and	$16	million	as	of	
December	31,	2021	and	December	31,	2020,	respectively.	
Accrued	liabilities	for	FHN’s	estimate	of	these	obligations	
are	reflected	in	other	liabilities	on	the	Consolidated	
Balance	Sheets.	Charges/expense	reversals	to	increase/
decrease	the	liability	are	included	within	other	income	on	
the	Consolidated	Statements	of	Income.	The	estimates	are	
based	upon	currently	available	information	and	fact	
patterns	that	exist	as	of	each	balance	sheet	date	and	
could	be	subject	to	future	changes.	Changes	to	any	one	of	
these	factors	could	significantly	impact	the	estimate	of	
FHN’s	liability.

Other	Disclosures

Indemnification	Agreements	and	Guarantees

In	the	ordinary	course	of	business,	FHN	enters	into	
indemnification	agreements	for	legal	proceedings	against	
its	directors	and	officers	and	standard	representations	and	
warranties	for	underwriting	agreements,	merger	and	
acquisition	agreements,	loan	sales,	contractual	
commitments,	and	various	other	business	transactions	or	
arrangements.	

The	extent	of	FHN’s	obligations	under	these	agreements	
depends	upon	the	occurrence	of	future	events;	therefore,	
it	is	not	possible	to	estimate	a	maximum	potential	amount	
of	payouts	that	could	be	required	by	such	agreements.

connection	with	mortgage	loans	securitized	by	the	buyer	
of	the	loans.	The	claims	generally	do	not	include	specific	
deficiencies	for	specific	loans	sold	by	FHN.	Instead,	the	
claims	generally	assert	that	FHN	is	liable	for	a	share	of	the	
claimant's	loss	estimated	by	assessing	the	totality	of	the	
other	whole	loans	sold	by	FHN	to	claimant	in	relation	to	
the	totality	of	the	larger	number	of	loans	securitized	by	
claimant.	FHN	is	unable	to	estimate	an	RPL	range	for	these	
matters	due	to	significant	uncertainties	regarding:	the	
number	of,	and	the	facts	underlying,	the	loan	originations	
which	claimants	assert	are	indemnifiable;	the	applicability	
of	FHN’s	contractual	indemnity	covenants	to	those	facts	
and	originations;	and,	in	those	cases	where	an	indemnity	
claim	may	be	supported,	whether	any	legal	defenses,	
counterclaims,	other	counter-positions,	or	third-party	
claims	might	eliminate	or	reduce	claims	against	FHN	or	
their	impact	on	FHN.

FHN	also	has	indemnification	claims	related	to	servicing	
obligations.	The	most	significant	is	from	Nationstar	
Mortgage	LLC,	currently	doing	business	as	“Mr.	Cooper.”	
Nationstar	was	the	purchaser	of	FHN’s	mortgage	servicing	
obligations	and	assets	in	2013	and	2014	and,	was	FHN’s	
subservicer.	Nationstar	asserts	several	categories	of	
indemnity	obligations	in	connection	with	mortgage	loans	
under	the	subservicing	arrangement	and	under	the	
purchase	transaction.	This	matter	currently	is	not	in	
litigation,	but	litigation	in	the	future	is	possible.	FHN	is	
unable	to	estimate	an	RPL	range	for	this	matter	due	to	
significant	uncertainties	regarding:	the	exact	nature	of	
each	of	Nationstar’s	claims	and	its	position	in	respect	of	
each;	the	number	of,	and	the	facts	underlying,	the	claimed	
instances	of	indemnifiable	events;	the	applicability	of	
FHN’s	contractual	indemnity	covenants	to	those	facts	and	
events;	and,	in	those	cases	where	the	facts	and	events	
might	support	an	indemnity	claim,	whether	any	legal	
defenses,	counterclaims,	other	counter-positions,	or	third-
party	claims	might	eliminate	or	reduce	claims	against	FHN	
or	their	impact	on	FHN.

FHN	has	additional	potential	exposures	related	to	its	
pre-2009	mortgage	businesses.	A	few	of	those	matters	
have	become	litigation	which	FHN	currently	estimates	are	
immaterial,	some	are	non-litigation	claims	or	threats,	
some	are	mere	subpoenas	or	other	requests	for	
information,	and	in	some	areas	FHN	has	no	indication	of	
any	active	or	threatened	dispute.	Some	of	those	matters	
might	eventually	result	in	settlements,	and	some	might	
eventually	result	in	adverse	litigation	outcomes,	but	none	
are	included	in	the	material	loss	contingency	liabilities	
mentioned	above	or	in	the	RPL	range	mentioned	above.

Mortgage	Loan	Repurchase	and	Foreclosure	Liability	

FHN’s	repurchase	and	foreclosure	liability,	primarily	
related	to	its	pre-2009	mortgage	businesses,	is	comprised	
of	accruals	to	cover	estimated	loss	content	in	the	active	
pipeline	(consisting	of	mortgage	loan	repurchase,	make-
whole,	foreclosure/servicing	demands	and	certain	related	

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table of Contents

NOTE	18—RETIREMENT	PLANS	&	OTHER	EMPLOYEE	BENEFITS

Note 18—Retirement Plans and Other Employee Benefits

Pension	Plan

FHN	sponsors	a	noncontributory,	qualified	defined	benefit	
pension	plan	to	employees	hired	or	re-hired	on	or	before	
September	1,	2007.	Pension	benefits	are	based	on	years	
of	service,	average	compensation	near	retirement	or	
other	termination,	and	estimated	social	security	benefits	
at	age	65.	Benefits	under	the	plan	are	“frozen”	so	that	
years	of	service	and	compensation	changes	after	2012	do	
not	affect	the	benefit	owed.	Minimum	contributions	are	
based	upon	actuarially	determined	amounts	necessary	to	
fund	the	total	benefit	obligation.	Decisions	to	contribute	
to	the	plan	are	based	upon	pension	funding	requirements	
under	the	Pension	Protection	Act,	the	maximum	amount	
deductible	under	the	Internal	Revenue	Code,	the	actual	
performance	of	plan	assets,	and	trends	in	the	regulatory	
environment.	FHN	made	a	contribution	of	$6	million	to	
the	qualified	pension	plan	in	2021,	and	no	contributions	
were	made	in	2020	and	2019.	Management	does	not	
currently	anticipate	that	FHN	will	make	a	contribution	to	
the	qualified	pension	plan	in	2022.		

FHN	also	maintains	non-qualified	plans	including	a	
supplemental	retirement	plan	that	covers	certain	
employees	whose	benefits	under	the	qualified	pension	
plan	have	been	limited	by	tax	rules.	These	other	non-
qualified	plans	are	unfunded,	and	contributions	to	these	
plans	cover	all	benefits	paid	under	the	non-qualified	plans.	
Payments	made	under	the	non-qualified	plans	were	
$5	million	for	2021.	FHN	anticipates	making	benefit	
payments	under	the	non-qualified	plans	of	$5	million	in	
2022.

Savings	Plan

FHN	provides	all	qualifying	full-time	employees	with	the	
opportunity	to	participate	in	FHN's	tax	qualified	401(k)	
savings	plan.	The	qualified	plan	allows	employees	to	defer	
receipt	of	earned	salary,	up	to	tax	law	limits,	on	a	tax-
advantaged	basis.	Accounts,	which	are	held	in	trust,	may	
be	invested	in	a	wide	range	of	mutual	funds	and	in	FHN	
common	stock.	Up	to	tax	law	limits,	FHN	provides	a	100%	
match	for	the	first	6%	of	salary	deferred,	with	company	
matching	contributions	invested	according	to	a	
participant’s	current	investment	election.	Through	a	non-
qualified	savings	restoration	plan,	FHN	provides	a	
restorative	benefit	to	certain	highly-compensated	
employees	who	participate	in	the	savings	plan	and	whose	
contribution	elections	are	capped	by	tax	limitations.

FHN	also	provides	“flexible	dollars”	to	assist	employees	
with	the	cost	of	annual	benefits	and/or	allow	the	
employee	to	contribute	to	his	or	her	qualified	savings	plan	
account.	These	“flexible	dollars”	are	pre-tax	contributions	
and	are	based	upon	the	employees’	years	of	service	and	

qualified	compensation.	Contributions	made	by	FHN	
through	the	flexible	benefits	plan	and	the	company	
matches	were	$51	million	for	2021,	$37	million	for	2020,	
and	$28	million	for	2019.

Other	Employee	Benefits

FHN	provides	postretirement	life	insurance	benefits	to	
certain	employees	and	also	provides	postretirement	
medical	insurance	benefits	to	retirement-eligible	
employees,	including	certain	prescription	drug	benefits.	
The	postretirement	medical	plan	is	contributory	with	FHN	
contributing	a	fixed	amount	for	certain	participants.	

Actuarial	Assumptions

FHN’s	process	for	developing	the	long-term	expected	rate	
of	return	of	pension	plan	assets	is	based	on	capital	market	
exposure	as	the	source	of	investment	portfolio	returns.	
Capital	market	exposure	refers	to	the	plan’s	allocation	of	
its	assets	to	asset	classes,	which	primarily	represent	fixed	
income	investments.	FHN	also	considers	expectations	for	
inflation,	real	interest	rates,	and	various	risk	premiums	
based	primarily	on	the	historical	risk	premium	for	each	
asset	class.	The	expected	return	is	based	upon	a	time	
horizon	of	30	years.	Given	its	funded	status,	the	asset	
allocation	strategy	for	the	qualified	pension	plan	utilizes	
fixed	income	instruments	that	closely	match	the	
estimated	duration	of	payment	obligations.	

The	discount	rates	for	the	three	years	ended	2021	for	
pension	and	other	benefits	were	determined	by	using	a	
hypothetical	AA	yield	curve	represented	by	a	series	of	
annualized	individual	discount	rates	from	one-half	to	30	
years.	The	discount	rates	are	selected	based	upon	data	
specific	to	FHN’s	plans	and	employee	population.	The	
bonds	used	to	create	the	hypothetical	yield	curve	were	
subjected	to	several	requirements	to	ensure	that	the	
resulting	rates	were	representative	of	the	bonds	that	
would	be	selected	by	management	to	fulfill	the	company’s	
funding	obligations.	In	addition	to	the	AA	rating,	only	non-
callable	bonds	were	included.	Each	bond	issue	was	
required	to	have	at	least	$300	million	par	outstanding	so	
that	each	issue	was	sufficiently	marketable.	Finally,	bonds	
more	than	two	standard	deviations	from	the	average	yield	
were	removed.	When	selecting	the	discount	rate,	FHN	
matches	the	duration	of	high	quality	bonds	with	the	
duration	of	the	obligations	of	the	plan	as	of	the	
measurement	date.	For	all	years	presented,	the	
measurement	date	of	the	benefit	obligations	and	net	
periodic	benefit	costs	was	December	31.

The	actuarial	assumptions	used	in	the	defined	benefit	
pension	plans	and	other	employee	benefit	plans	were	as	
follows:

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Table	8.18.1

Discount	rate

Qualified	pension

Nonqualified	
pension

Other	nonqualified	
pension

Postretirement	
benefits
Expected	long-
term	rate	of	
return
Qualified	pension/
postretirement	
benefits

Postretirement	
benefit	(retirees	
post	
January	1,	1993)

Postretirement	
benefit	(retirees	
prior	to	
January	1,	1993)

Table of Contents

NOTE	18—RETIREMENT	PLANS	&	OTHER	EMPLOYEE	BENEFITS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

ACTUARIAL	ASSUMPTIONS	FOR	DEFINED	BENEFIT	PLANS

2021

2.95%

2.65%

1.99%

Benefit	Obligations
2020

2.63%

2.24%

1.41%

2019

3.31%

3.08%

2.57%

2021

2.64%

2.24%

1.41%

Net	Periodic	Benefit	Cost
2020

3.31%

3.08%

2.57%

2019

4.43%

4.26%

3.83%

2.43%-3.07%

1.92%	-	2.81%

2.85%	-	3.44%

1.93%-2.81%

2.87%	-	3.44%

4.04%	-	4.56%

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Since	the	benefits	in	the	defined	benefit	pension	plan	are	
frozen,	the	rate	of	compensation	increase	has	no	effect	on	
qualified	pension	benefits.

FHN	has	one	pension	plan	where	participants'	benefits	are	
affected	by	interest	crediting	rates.	The	plan's	projected	
benefit	obligation	as	of	December	31,	2021,	2020	and	
2019	and	interest	crediting	rates	for	the	respective	years	
were	as	follows:	

2.30%

3.45%

4.80%

5.80%

6.40%

6.85%

1.00%

0.90%

0.05%

Table	8.18.2

PROJECTED	BENEFIT	OBLIGATION	
&	CREDITING	RATE

(Dollars	in	millions)

2021

2020

2019

Projected	benefit	obligation

$	

12	

$	

15	

$	

16	

Interest	crediting	rate

	9.07	%

	8.20	%

	9.66	%

The	components	of	net	periodic	benefit	cost	for	the	plan	
years	2021,	2020	and	2019	were	as	follows:

Table	8.18.3

COMPONENTS	OF	NET	PERIODIC	BENEFIT	COST

(Dollars	in	millions)

Components	of	net	periodic	benefit	cost

Interest	cost

Expected	return	on	plan	assets

Amortization	of	unrecognized:

Actuarial	(gain)	loss

Net	periodic	benefit	cost

Pension	Benefits
2020

2021

2019

2021

Other	Benefits
2020

2019

$	

$	

17	 $	
(20)	

10	

7	 $	

24	 $	

(26)	

13	

11	 $	

30	 $	
(37)	

10	

3	 $	

1	 $	
(1)	

—	
—	 $	

1	 $	

(1)	

—	

—	 $	

1	

(1)	

—	

—	

The	long-term	expected	rate	of	return	is	applied	to	the	
market-related	value	of	plan	assets	in	determining	the	
expected	return	on	plan	assets.	FHN	determines	the	
market-related	value	of	plan	assets	using	a	hybrid	
methodology	which	recognizes	liability-hedging	assets	at	
current	fair	value	while	return-seeking	assets	use	a	
calculated	value	that	recognizes	changes	in	fair	value	over	
five	years,	as	permitted	by	GAAP.

FHN	utilizes	a	spot	rate	approach	which	applies	duration-
specific	rates	from	the	full	yield	curve	to	estimated	future	
benefit	payments	for	the	determination	of	interest	cost.

The	following	tables	set	forth	the	plans’	benefit	
obligations	and	plan	assets	for	2021	and	2020:

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Table of Contents

NOTE	18—RETIREMENT	PLANS	&	OTHER	EMPLOYEE	BENEFITS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table	8.18.4

BENEFIT	OBLIGATIONS	&	PLAN	ASSETS

(Dollars	in	millions)

Change	in	benefit	obligation
Benefit	obligation,	beginning	of	year

Interest	cost

Actuarial	(gain)	loss	(a)

Actual	benefits	paid

Benefit	obligation,	end	of	year

Change	in	plan	assets
Fair	value	of	plan	assets,	beginning	of	year

Actual	return	on	plan	assets

Employer	contributions
Actual	benefits	paid	–	settlement	payments

Actual	benefits	paid	–	other	payments

Premium	paid	for	annuity	purchase	(b)

Fair	value	of	plan	assets,	end	of	year

Funded	(unfunded)	status	of	the	plans

Amounts	recognized	in	the	Balance	Sheets
Other	assets

Other	liabilities

Net	asset	(liability)	at	end	of	year

Pension	Benefits

Other	Benefits

2021

2020

2021

2020

$	

$	

$	

$	

$	

$	

$	

893	 $	

836	 $	

17	

(26)	

(39)	
845	 $	

896	 $	
(18)	

10	
(3)	

(2)	

(34)	
849	 $	
4	 $	

37	 $	
(33)	

4	 $	

24	

70	

(37)	
893	 $	

826	 $	
103	

4	
(36)	

(1)	

—	
896	 $	
3	 $	

40	 $	
(37)	

3	 $	

46	 $	

1	

(5)	

(1)	
41	 $	

23	 $	

3	

1	
(1)	

—	

—	
26	 $	
(15)	 $	

23	 $	
(38)	
(15)	 $	

42	

1	

4	

(1)	

46	

20	

3	

1	
(1)	

—	

—	

23	

(23)	

20	

(43)	

(23)	

(a) Variances	in	the	actuarial	(gain)	loss	are	due	to	normal	activity	such	as	changes	in	discount	rates,	updates	to	participant	demographic	information	and	

revisions	to	life	expectancy	assumptions.

(b) 2021	amount	represents	settlements	of	certain	retired	participants	in	the	qualified	pension	plan	that	occurred	during	the	year.

The	projected	benefit	obligation	for	unfunded	plans	was	as	follows:

Table	8.18.5

(Dollars	in	millions)

BENEFIT	OBLIGATION	-	UNFUNDED	PLANS	

Pension	Benefits

Other	Benefits

2021

2020

2021

2020

Projected	benefit	obligation

$	

33	 $	

37	 $	

38	 $	

43	

The	qualified	pension	plan	was	overfunded	by	$37	million	
and	$41	million	as	of	December	31,	2021	and	2020,	
respectively.	Because	of	the	pension	freeze	at	the	end	of	
2012,	as	of	both	December	31,	2021	and	2020,	the	
pension	benefit	obligation	is	equivalent	to	the	
accumulated	benefit	obligation.	FHN's	funded	post	
retirement	plan	was	also	in	an	overfunded	status	as	of	
December	31,	2021	and	2020.

Unrecognized	actuarial	gains	and	losses	and	unrecognized	
prior	service	costs	and	credits	are	recognized	as	a	
component	of	accumulated	other	comprehensive	income.	
Balances	reflected	in	accumulated	other	comprehensive	
income	on	a	pre-tax	basis	for	the	years	ended	
December	31,	2021	and	2020	consist	of:

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NOTE	18—RETIREMENT	PLANS	&	OTHER	EMPLOYEE	BENEFITS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table	8.18.6

PRE-TAX	ACTUARIAL	GAINS	(LOSSES)	REFLECTED	IN	AOCI

(Dollars	in	millions)
Amounts	recognized	in	accumulated	other	
comprehensive	income
Net	actuarial	(gain)	loss

Pension	Benefits

Other	Benefits

2021

2020

2021

2020

$	

342	 $	

342	 $	

(6)	 $	

1	

The	pre-tax	amounts	recognized	in	other	comprehensive	income	during	2021,	2020,	and	2019	were	as	follows:

Table	8.18.7

PRE-TAX	AMOUNTS	RECOGNIZED	IN	OCI

(Dollars	in	millions)
Changes	in	plan	assets	and	benefit	obligation	
recognized	in	other	comprehensive	income
Net	actuarial	(gain)	loss	arising	during	measurement	
period
Items	amortized	during	the	measurement	period:

Pension	Benefits

Other	Benefits

2021

2020

2019

2021

2020

2019

$	

13	 $	

(8)	 $	

(14)	 $	

(7)	 $	

3	 $	

5	

Net	actuarial	gain	(loss)

(10)	

Total	recognized	in	other	comprehensive	income

$	

3	 $	

(13)	 	

(21)	 $	

(10)	
(24)	 $	

—	
(7)	 $	

—	

3	 $	

— 
5	

FHN	utilizes	the	minimum	amortization	method	in	
determining	the	amount	of	actuarial	gains	or	losses	to	
include	in	plan	expense.	Under	this	approach,	the	net	
deferred	actuarial	gain	or	loss	that	exceeds	a	threshold	is	
amortized	over	the	average	remaining	service	period	of	
active	plan	participants.	The	threshold	is	measured	as	the	
greater	of:	10%	of	a	plan’s	projected	benefit	obligation	as	
of	the	beginning	of	the	year	or	10%	of	the	market	related	
value	of	plan	assets	as	of	the	beginning	of	the	year.	FHN	
amortizes	actuarial	gains	and	losses	using	the	estimated	
average	remaining	life	expectancy	of	the	remaining	
participants	since	all	participants	are	considered	inactive	
due	to	the	freeze.

The	following	table	provides	detail	on	expected	benefit	
payments,	which	reflect	expected	future	service,	as	
appropriate:

Table	8.18.8

EXPECTED	BENEFIT	PAYMENTS

(Dollars	in	millions)

2022

2023

2024

2025

2026

2027-2031

Plan	Assets

Pension
Benefits

Other
Benefits

$	

40	 $	

42	

43	

45	

46	

232	

2	

2	

2	

2	

2	

11	

FHN’s	overall	investment	goal	is	to	create,	over	the	life	of	
the	pension	plan	and	retiree	medical	plan,	an	adequate	

pool	of	sufficiently	liquid	assets	to	support	the	qualified	
pension	benefit	obligations	to	participants,	retirees,	and	
beneficiaries,	as	well	as	to	partially	support	the	medical	
obligations	to	retirees	and	beneficiaries.	Thus,	the	
qualified	pension	plan	and	retiree	medical	plan	seek	to	
achieve	a	level	of	investment	return	consistent	with	
changes	in	projected	benefit	obligations.

Qualified	pension	plan	assets	primarily	consist	of	fixed	
income	securities	which	include	U.S.	treasuries,	corporate	
bonds	of	companies	from	diversified	industries,	municipal	
bonds,	and	foreign	bonds.	Fixed	income	investments	
generally	have	long	durations	consistent	with	the	
estimated	pension	liabilities	of	FHN.	This	duration-
matching	strategy	is	intended	to	hedge	substantially	all	of	
the	plan’s	risk	associated	with	future	benefit	payments.	
Retiree	medical	funds	are	kept	in	short-term	investments,	
primarily	money	market	funds	and	mutual	funds.	On	
December	31,	2021	and	2020,	FHN	did	not	have	any	
significant	concentrations	of	risk	within	the	plan	assets	
related	to	the	pension	plan	or	the	retiree	medical	plan.

The	fair	value	of	FHN’s	pension	plan	assets	at	
December	31,	2021	and	2020,	by	asset	category	classified	
using	the	Fair	Value	measurement	hierarchy,	is	shown	in	
the	tables	below.	See	Note	24	–	Fair	Value	of	Assets	and	
Liabilities	for	more	details	about	fair	value	measurements.	

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Tables	8.18.9a-b

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	18—RETIREMENT	PLANS	&	OTHER	EMPLOYEE	BENEFITS

FAIR	VALUE	OF	PENSION	ASSETS

December	31,	2021

(Dollars	in	millions)

Level	1

Level	2

Level	3

Total

Cash	equivalents	and	money	market	funds

$	

45	 $	

—	 $	

—	 $	

Fixed	income	securities:

U.S.	treasuries

Corporate,	municipal	and	foreign	bonds

Common	and	collective	funds:

Fixed	income

Total

(Dollars	in	millions)

Cash	equivalents	and	money	market	funds

Fixed	income	securities:

U.S.	treasuries

Corporate,	municipal	and	foreign	bonds

Common	and	collective	funds:

Fixed	income

Total

—	

—	

—	

45	 $	

15	

445	

344	

804	 $	

—	

—	

—	

—	 $	

December	31,	2020

Level	1

Level	2

Level	3

Total

23	 $	

—	 $	

—	 $	

$	

$	

—	

—	

—	

$	

23	 $	

6	

488	

379	

873	 $	

—	

—	

—	

—	 $	

45	

15	

445	

344	

849	

23	

6	

488	

379	

896	

The	Pension	and	Savings	Investment	Committees,	
comprised	of	senior	managers	within	the	organization,	
meet	regularly	to	review	asset	performance	and	potential	
portfolio	revisions.	

Adjustments	to	the	qualified	pension	plan	asset	allocation	
primarily	reflect	changes	in	anticipated	liquidity	needs	for	
plan	benefits.

Tables	8.18.10a-b

The	fair	value	of	FHN’s	retiree	medical	plan	assets	at	
December	31,	2021	and	2020	by	asset	category	are	as	
follows:

(Dollars	in	millions)

Mutual	funds:

Equity	mutual	funds

Fixed	income	mutual	funds

Total

(Dollars	in	millions)

Mutual	funds:

Equity	mutual	funds
Fixed	income	mutual	funds

Total

FAIR	VALUE	OF	RETIREE	MEDICAL	PLAN	ASSETS

Level	1

Level	2

Level	3

Total

December	31,	2021

$	

$	

$	

$	

17	 $	

9	

26	 $	

—	 $	

—	

—	 $	

—	 $	

—	

—	 $	

Level	1

Level	2

Level	3

Total

December	31,	2020

15	 $	

8	

23	 $	

—	 $	
—	

—	 $	

—	 $	
—	

—	 $	

17	

9	

26	

15	
8	

23	

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NOTE	19—STOCK	OPTIONS,	RESTRICTED	STOCK,	&	DIVIDEND	REINVESTMENT	PLANS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 19—Stock Options, Restricted Stock, and Dividend Reinvestment Plans 

Equity	Compensation	Plans

FHN	currently	has	one	plan	which	authorizes	the	grant	of	
new	stock-based	awards,	the	2021	Incentive	Plan	(the	IP).	
New	awards	under	the	IP	may	be	granted	to	any	of	FHN's	
directors,	officers,	or	associates.	The	IP	was	approved	by	
shareholders	in	April	2021.	Most	awards	outstanding	at	
year	end	were	granted	under	predecessor		plans	which	
are	no	longer	active.	

The	IP	authorizes	a	broad	range	of	award	types,	including	
restricted	shares,	stock	units,	cash	units,	and	stock	
options.	Stock	units	may	be	paid	in	shares	or	cash,	
depending	upon	the	terms	of	the	award.	The	IP	also	
authorizes	the	grant	of	stock	appreciation	rights,	though	
no	such	grants	have	been	made	under	the	IP	or	recent	
predecessor	plans.	Unvested	awards	have	service	and/or	
performance	conditions	which	must	be	met	in	order	for	
the	shares	to	vest.	Awards	generally	have	service-vesting	
conditions,	meaning	that	the	associate	must	remain	
employed	by	FHN	for	certain	periods	in	order	for	the	
award	to	vest.	Some	outstanding	awards	also	have	
performance	conditions,	and	one	outstanding	award	has	
performance	conditions	associated	with	FHN’s	stock	price.	
FHN	operates	the	IP	by	establishing	award	programs,	each	
of	which	is	intended	to	cover	a	specific	need.	Programs	
are	created,	changed,	or	terminated	as	needs	change.

On	December	31,	2021,	there	were	12,329,976	shares	
available	for	new	awards	under	the	IP.	This	includes	the	
new/additional	shares	originally	authorized	under	the	IP	
along	with	shares	underlying	ECP	awards	that	have	been	
forfeited	or	canceled	since	the	IP	was	approved	by	
shareholders,	net	of	shares	underlying	IP	awards	that	are	
outstanding	or	have	been	paid.	

Service	condition	full-value	awards

Awards	may	be	granted	with	service	conditions	only.	In	
recent	years,	programs	using	these	awards	have	included	
annual	programs	for	executives	and	selected	management	
associates,	a	mandatory	deferral	program	for	executives	
tied	to	annual	bonuses	earned,	other	mandatory	or	
elective	deferral	programs,	various	retention	programs,	
and	special	hiring-incentive	situations.	Details	of	the	
awards	vary	by	program,	but	most	are	settled	in	shares	at	
vesting	rather	than	cash,	and	vesting	generally	begins	no	
earlier	than	the	third	anniversary	of	grant	and	rarely	
extends	beyond	the	fifth	anniversary	of	grant.	

Performance	condition	awards

Under	FHN’s	long-term	incentive	and	corporate	
performance	programs,	performance	stock	units	(PSUs)	
(executives)	and	cash	units	(selected	management	
employees)	are	granted	annually	and	vest	only	if	
predetermined	performance	measures	are	met.	The	
measures	are	changed	each	year	based	on	goals	and	
circumstances	prevailing	at	the	time	of	grant.	In	recent	

years	the	performance	periods	have	been	three	years,	
with	service-vesting	near	the	third	anniversary	of	the	
grant.	PSUs	granted	from	2014	to	2020	have	a	post-vest	
holding	period	of	two	years.	PSUs	granted	after	2020	no	
longer	have	the	2-year	holding	period.	Recent	annual	
performance	awards	require	pro-rated	forfeiture	for	
performance	falling	between	a	threshold	level	and	a	
maximum.	Performance	awards	sometimes	are	used	to	
provide	a	narrow,	targeted	incentive	to	a	single	person	or	
small	group;	one	such	award	which	includes	a	market	
performance	condition	to	FHN’s	CEO	is	discussed	in	the	
next	paragraph.	Of	the	annual	program	awards	paid	
during	2021	or	outstanding	on	December	31,	2021:	the	
2016	units	vested	in	2019	and	their	two	year	post-vesting	
holding	period	ended	during	2021,	2017	and	2018	units	
vested	in	2020	and	2021	at	the	104.2%		and	133.3%	
payout	level,	respectively,	and	remain	in	a	two	year	post-
vesting	holding	period;	the	three-year	performance	period	
of	the	2019	units	has	ended	but	performance	is	measured	
relative	to	peers	and	has	not	yet	been	determined;	and,	
the	three-year	performance	periods	for	the	2020	and	
2021	units	have	not	ended.

Market	condition	award

In	2016,	FHN	made	a	special	grant	of	performance	stock	
units	to	FHN’s	CEO	which	will	vest	at	the	end	of	a	
performance	period	of	seven	years.	The	award	has	no	
provision	for	pro-rated	payment	based	on	partial	
performance.	The	award’s	performance	goal	is	based	on	
achievement	of	a	specific	level	of	total	shareholder	return	
during	the	performance	period.	

Director	awards

Non-employee	directors	receive	cash	and	annual	grants	of	
service-conditioned	stock	units	under	a	program	approved	
by	the	board	of	directors.	Director	stock	units	granted	
prior	to	the	IBKC	merger	vest	in	the	year	following	the	
year	of	grant,	require	a	payment	deferral	of	two	years,	
and	settle	in	shares	after	the	deferral	period.	Director	
stock	units	granted	after	the	IBKC	merger	no	longer	have	
the	2-year	holding	period.	In	2021	and	2020,	each	director	
received	$122,000	or	prorated	equivalent	of	stock	units,	
representing	a	portion	of	their	annual	retainer.	Effective	
with	the	IBKC	merger	on	July	1,	2020,	the	annual	grant	of	
director	stock	units	was	increased	to	$122,000	or	prorated	
equivalent	of	stock	units	and	all	directors	then	in	office	
received	a	supplemental	grant	to	bring	all	directors	up	to	
the	new	annual	grant	level.	Prior	to	2005,	directors	could	
elect	to	defer	cash	compensation	in	the	form	of	discount-
priced	stock	options,	some	of	which	remain	outstanding.

Stock	and	stock	unit	awards.	A	summary	of	restricted	and	
performance	stock	and	unit	activity	during	the	year	ended	
December	31,	2021,	is	presented	below:

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NOTE	19—STOCK	OPTIONS,	RESTRICTED	STOCK,	&	DIVIDEND	REINVESTMENT	PLANS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Table	8.19.1

RESTRICTED	AND	PERFORMANCE	EQUITY	AWARD	ACTIVITY

January	1,	2021

Shares/units	granted

Shares/units	vested/distributed

Shares/units	canceled

December	31,	2021

Shares/
Units	(a)

Weighted	average
grant	date	fair	value
(per	share)	(b)

8,270,216	 $	

4,330,371	

(637,689)	

(2,666,010)	

9,296,888	 $	

12.47	

13.56	

12.31	

13.05	

13.14	

(a) Includes	only	units	that	settle	in	shares;	nonvested	performance	units	are	included	at	100%	payout	level.
(b) The	weighted	average	grant	date	fair	value	for	shares/units	granted	in	2020	and	2019	was	$12.47	and	$16.25,	respectively.

On	December	31,	2021,	there	was	$73	million	of	
unrecognized	compensation	cost	related	to	nonvested	
restricted	stock	awards.	That	cost	is	expected	to	be	
recognized	over	a	weighted-average	period	of	two	years.	
The	total	grant	date	fair	value	of	shares	vested	during	
2021,	2020	and	2019,	was	$36	million,	$24	million,	and	
$15	million,	respectively.

Stock	option	awards

In	2021	FHN	ended	its	only	remaining	stock	option	
program,	making	only	one	grant	related	to	a	2020	
commitment.	Options	under	that	program,	for	executives,	
have	service-vesting	requirements	and	seven-year	terms.	

In	the	past,	option	programs	varied	widely	in	their	uses	
and	terms,	and	many	old-program	options,	granted	under	
the	ECP	or	its	predecessor	plans,	remain	outstanding	
today.	All	options	granted	since	2005	provide	for	the	
issuance	of	FHN	common	stock	at	a	price	fixed	at	its	fair	
market	value	on	the	grant	date.	Except	for	converted	
options	and	a	special	retention	stock	option	award	to	the	
CEO	in	2016,	all	options	granted	since	2008	vest	fully	no	

Table	8.19.2

later	than	the	fourth	anniversary	of	grant,	and	all	such	
options	expire	seven	years	from	the	grant	date.	CBF	
converted	options	and	IBKC	converted	options	granted	
prior	to	November	3,	2019	(the	merger	agreement	date)	
are	fully	vested	and	expire	ten	years	from	grant	date.	IBKC	
converted	options	granted	subsequent	to	the	merger	
agreement	vest	fully	no	later	than	the	fifth	anniversary	of	
the	grant	date	and	expire	ten	years	from	grant	date.	The	
2016	retention	award	vests	beginning	on	the	fourth	
anniversary	of	grant	and	extends	through	the	sixth	
anniversary	of	grant.	A	deferral	program,	which	was	
discontinued	in	2005,	allowed	for	foregone	compensation	
plus	the	exercise	price	to	equal	the	fair	market	value	of	
the	stock	on	the	date	of	grant	if	the	grantee	agreed	to	
receive	the	options	in	lieu	of	compensation.	Deferral	
options	still	outstanding	expire	20	years	from	the	grant	
date.

The	summary	of	stock	option	activity	for	the	year	ended	
December	31,	2021,	is	shown	below:

STOCK	OPTION	ACTIVITY

Options
Outstanding

Weighted
Average
Exercise	Price
(per	share)

Weighted	Average
Remaining
Contractual	Term
(years)

Aggregate
Intrinsic	Value
(millions)

January	1,	2021

Options	granted

Options	exercised

Options	expired/canceled

December	31,	2021
Options	exercisable

Options	expected	to	vest

7,749,082	 $	

155,124	

(2,302,642)	

(620,635)	

4,980,929	 $	

3,697,062	

1,283,867	

15.20	

14.44	

11.88	

22.44	

15.81	

15.95	

15.15	

3.99 $	

3.51 	

4.39 	

7	

6	

1	

The	total	intrinsic	value	of	options	exercised	during	2021,	
2020	and	2019	was	$12	million,	$3	million,	and	$4	million,	
respectively.	On	December	31,	2021,	there	was	less	than	
$1	million	of	unrecognized	compensation	cost	related	to	

nonvested	stock	options.	That	cost	is	expected	to	be	
recognized	over	a	weighted-average	period	of	2.7	years.

FHN	granted	or	converted	155,124,	4,182,737	and	
530,787	stock	options	with	a	weighted	average	fair	value	

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NOTE	19—STOCK	OPTIONS,	RESTRICTED	STOCK,	&	DIVIDEND	REINVESTMENT	PLANS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

of	$3.39,	$2.13,	and	$2.69	per	option	at	grant	date	in	
2021,	2020	and	2019,	respectively.

converted	in	2021,	2020,	and	2019	with	the	following	
assumptions:

FHN	used	the	Black-Scholes	Option	Pricing	Model	to	
estimate	the	fair	value	of	stock	options	granted	or	

Table	8.19.3

STOCK	OPTION	FAIR	VALUE	ASSUMPTIONS

Expected	dividend	yield
Expected	weighted-average	lives	of	options	granted
Expected	weighted-average	volatility
Expected	volatility	range
Risk-free	interest	rate

2021
4.16%
6.29	years
38.44%
37.86%-39.02%
0.62%

2020
3.77%
6.25	years
23.94%
23.32	-	24.56%
1.47%

2019
3.63%
6.24	years
24.76%
	23.07	-	26.45%
2.53%

issuance	of	FHN	common	stock	which	may	be	required	as	
a	result	of	stock	based	compensation	awards.	FHN	has	
obtained	authorization	from	the	Board	of	Directors	to	
repurchase	up	to	certain	numbers	of	shares	related	to	
issuance	under	the	IP	and	several	older	stock	award	plans.	
These	authorizations	are	automatically	adjusted	for	stock	
splits	and	stock	dividends.	Repurchases	are	authorized	to	
be	made	in	the	open	market	or	through	privately	
negotiated	transactions	and	will	be	subject	to	market	
conditions,	accumulation	of	excess	equity,	legal	and	
regulatory	restrictions,	and	prudent	capital	management.	
FHN	does	not	currently	expect	to	repurchase	a	material	
number	of	shares	under	the	compensation	plan-related	
repurchase	program	during	2022.

Dividend	reinvestment	plan

The	Dividend	Reinvestment	and	Stock	Purchase	Plan	
authorizes	the	sale	of	FHN’s	common	stock	from	stock	
acquired	on	the	open	market	to	shareholders	who	choose	
to	invest	all	or	a	portion	of	their	cash	dividends	or	make	
optional	cash	payments	of	$25	to	$10,000	per	quarter	
without	paying	commissions.	The	price	of	stock	purchased	
on	the	open	market	is	the	average	price	paid.	

Expected	lives	of	options	granted	are	determined	based	
on	the	vesting	period,	historical	exercise	patterns	and	
contractual	term	of	the	options.	FHN	uses	a	blend	of	
historical	and	implied	volatility	in	determining	expected	
volatility.	A	portion	of	the	weighted	average	volatility	rate	
is	derived	by	compiling	daily	closing	stock	prices	over	a	
historical	period	approximating	the	expected	lives	of	the	
options.	Additionally,	because	of	market	volatility	due	to	
economic	conditions	and	the	impact	on	stock	prices	of	
financial	institutions,	FHN	also	incorporates	a	measure	of	
implied	volatility	so	as	to	incorporate	more	recent	market	
conditions	in	the	estimation	of	future	volatility.

Phantom	stock	awards

As	a	result	of	the	IBKC	merger,	FHN	assumed	phantom	
stock	awards	under	various	plans	to	officers	and	other	key	
associates.	The	awards	are	subject	to	a	vesting	period	of	
five	years	and	are	paid	out	in	cash	upon	vesting.	The	
amount	paid	per	vesting	period	is	calculated	as	the	
number	of	vested	share	equivalents	multiplied	by	closing	
market	price	of	a	share	of	the	Company's	common	stock	
on	the	vesting	date.	Share	equivalents	are	calculated	on	
the	date	of	grant	as	the	total	award's	dollar	value	divided	
by	the	closing	market	price	of	a	share	of	the	Company's	
common	stock	on	the	grant	date.	As	of	December	31,	
2021,	there	were	461,142	share	equivalents	of	phantom	
stock	awards	outstanding.	See	Note	1	-	Significant	
Accounting	Policies	for	more	discussion	on	FHN's	phantom	
stock	awards.	

Compensation	Cost

The	compensation	cost	that	has	been	included	in	the	
Consolidated	Statements	of	Income	pertaining	to	stock-
based	awards	was	$43	million,	$32	million,	and	$22	
million	for	2021,	2020,	and	2019,	respectively.	The	
corresponding	total	income	tax	benefits	recognized	were	
$10	million	in	2021,	$8	million	in	2020,	and	$6	million	in	
2019.

Authorization

Consistent	with	Tennessee	state	law,	only	authorized,	but	
unissued,	stock	may	be	utilized	in	connection	with	any	

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NOTE	20—BUSINESS	SEGMENT	INFORMATION

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 20—Business Segment Information

FHN's	operating	segments	are	composed	of	the	following:

• Regional	Banking	segment	offers	financial	products	

and	services,	including	traditional	lending	and	deposit	
taking,	to	consumer	and	commercial	clients	primarily	
in	the	southern	U.S.	and	other	selected	markets.	
Regional	Banking	also	provides	investment,	wealth	
management,	financial	planning,	trust	and	asset	
management	services	for	consumer	clients.

• Specialty	Banking	segment	consists	of	lines	of	

business	that	deliver	product	offerings	and	services	
with	specialized	industry	knowledge.		Specialty	
Banking’s	lines	of	business	include	asset-based	
lending,	mortgage	warehouse	lending,	commercial	
real	estate,	franchise	finance,	correspondent	banking,	
equipment	finance,	mortgage,	and	title	insurance.	In	
addition	to	traditional	lending	and	deposit	taking,	
Specialty	Banking	also	delivers	treasury	management	
solutions,	loan	syndications,	and	international	
banking.		Additionally,	Specialty	Banking	has	a	line	of	
business	focused	on	fixed	income	securities	sales,	
trading,	underwriting,	and	strategies	for	institutional	
clients	in	the	U.S.	and	abroad,	as	well	as	loan	sales,	
portfolio	advisory	services,	and	derivative	sales.

• Corporate	segment	consists	primarily	of	corporate	

support	functions	including	risk	management,	audit,	
accounting,	finance,	executive	office,	and	corporate	
communications.	Shared	support	services	such	as	
human	resources,	properties,	technology,	credit	risk	
and	bank	operations	are	allocated	to	the	activities	of	
Regional	Banking,	Specialty	Banking	and	Corporate.		
Additionally,	the	Corporate	segment	includes	
centralized	management	of	capital	and	funding	to	
support	the	business	activities	of	the	company	

including	management	of	wholesale	funding,	liquidity,	
and	capital	management	and	allocation.		The	
Corporate	segment	also	includes	the	revenue	and	
expense	associated	with	run-off	businesses	such	as	
pre-2009	mortgage	banking	elements,	run-off	
consumer	and	trust	preferred	loan	portfolios,	and	
other	exited	businesses.

Periodically,	FHN	adapts	its	segments	to	reflect	
managerial	or	strategic	changes.	During	2020,	FHN	
reorganized	its	internal	management	structure	and,	
accordingly,	its	segment	reporting	structure.	Historically,	
FHN's	reportable	business	segments	were	Regional	
Banking,	Fixed	Income,	Corporate,	and	Non-strategic.	The	
closing	of	the	FHN	and	IBKC	merger-of-equals	transaction	
prompted	organizational	changes	to	better	integrate	and	
execute	the	combined	Company's	strategic	priorities	
across	all	lines	of	businesses.	As	a	result,	segment	
information	for	2020	has	been	reclassified	to	conform	to	
the	current	period	presentation.	

FHN	may	also	modify	its	methodology	of	allocating	
expenses	and	equity	among	segments	which	could	change	
historical	segment	results.	Business	segment	revenue,	
expense,	asset,	and	equity	levels	reflect	those	which	are	
specifically	identifiable	or	which	are	allocated	based	on	an	
internal	allocation	method.	Because	the	allocations	are	
based	on	internally	developed	assignments	and	
allocations,	to	an	extent	they	are	subjective.	Generally,	all	
assignments	and	allocations	have	been	consistently	
applied	for	all	periods	presented.	

The	following	tables	present	financial	information	for	each	
reportable	business	segment	for	the	years	ended	
December	31:

Tables	8.20.1a-b-c	

(Dollars	in	millions)

Net	interest	income	(expense)

Provision	for	credit	losses

Noninterest	income

Noninterest	expense	(b)(c)(f)

Income	(loss)	before	income	taxes

Income	tax	expense	(benefit)

Net	income	(loss)

Average	assets

Depreciation	and	amortization

Expenditures	for	long-lived	assets

SEGMENT	FINANCIAL	INFORMATION

2021

Regional	Banking

Specialty	Banking

Corporate

Consolidated

$	

$	

$	

1,764	 $	

(229)	 	

438	

1,151	

1,280	

298	

982	 $	

45,445	 $	

(71)	 	

27	

619	 $	

(64)	 	

597	

571	

709	

171	

538	 $	

(389)	 $	

(17)	 	

41	

374	

(705)	 	

(195)	 	

(510)	 $	

1,994	

(310)	

1,076	

2,096	

1,284	

274	

1,010	

20,803	 $	

21,361	 $	

87,609	

(2)	 	

3	

101	

7	

28	

37	

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NOTE	20—BUSINESS	SEGMENT	INFORMATION

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(Dollars	in	millions)
Net	interest	income	(expense)

Provision	for	credit	losses	(e)

Noninterest	income	(a)

Noninterest	expense	(b)(c)(d)

Income	(loss)	before	income	taxes

Income	tax	expense	(benefit)

Net	income	(loss)

Average	assets

Depreciation	and	amortization

Expenditures	for	long-lived	assets

(Dollars	in	millions)
Net	interest	income	(expense)

Provision	for	credit	losses

Noninterest	income

Noninterest	expense	(b)(c)(d)(f)

Income	(loss)	before	income	taxes

Income	tax	expense	(benefit)

Net	income	(loss)

Average	assets

Depreciation	and	amortization

Expenditures	for	long-lived	assets

Regional	Banking

2020
Specialty	Banking

Corporate

Consolidated

$	

1,264	 $	

572	 $	

(174)	 $	

392	

345	

944	

273	

56	

217	 $	

32,782	 $	

(42)	 	

283	

116	

576	

494	

538	

131	

407	 $	

(5)	 	

571	

280	

122	

(111)	 	

233	 $	

1,662	

503	

1,492	

1,718	

933	

76	

857	

19,822	 $	

11,742	 $	

64,346	

4	

6	

84	

90	

46	

379	

Regional	Banking

2019
Specialty	Banking

833	 $	

389	 $	

24	

293	

678	

424	

97	

327	 $	

18,236	 $	

22	

29	

37	

315	

347	

320	

79	

241	 $	

15,517	 $	

14	

4	

Corporate

Consolidated

(12)	 $	

(16)	 	

46	

208	

(158)	 	

(42)	 	

(116)	 $	

7,991	 $	

29	

16	

1,210	

45	

654	

1,233	

586	

134	

452	

41,744	

65	

49	

$	

$	

$	

$	

$	

(a)	 2020	includes	a	$533	million	purchase	accounting	gain	associated	with	the	IBKC	merger	in	the	Corporate	segment.
(b)	 2019	includes	restructuring-related	costs	associated	with	efficiency	initiatives;	refer	to	Note	25	-	Restructuring,	Repositioning,	and	Efficiency	for	

additional	information.	2021,	2020	and	2019	include	merger-related	expenses;	refer	to	Note	2	-	Acquisitions	and	Divestitures	for	additional	information.

(c)	 2021	and	2020	includes$37	million	and	$13	million,	respectively,	in	asset	impairments	related	to	IBKC	merger	integration	efforts	in	the	Corporate	

segment.	2019	includes	$25	million	of	asset	impairments	associated	with	acquisition,	restructuring,	and	rebranding	initiatives.

(d)	 2020	and	2019	include	$41	million	and	$11	million,	respectively,	of	contributions	to	FHN's	foundations.	
(e)	 Increase	in	provision	for	credit	losses	in	2020	is	primarily	due	to	the	provision	related	to	non-PCD	loans	acquired	in	the	IBKC	merger	and	Truist	branch	

acquisition	and	the	economic	forecast	attributable	to	the	COVID-19	pandemic.	

(f)	 2021	and	2019	include	$19	million	and	$4	million,	respectively,	in	derivative	valuation	adjustments	related	to	prior	sales	of	Visa	Class	B	shares	in	the	

Corporate	segment.

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NOTE	20—BUSINESS	SEGMENT	INFORMATION

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

The	following	tables	reflect	a	disaggregation	of	FHN’s	noninterest	income	by	major	product	line	and	reportable	segment	for	
the	years	ended	December	31,	2021,	2020,	and	2019:

NONINTEREST	INCOME	DETAIL	BY	SEGMENT

December	31,	2021

Regional	Banking

Specialty	Banking

Corporate

Consolidated

Tables	8.20.2a-b-c	

(Dollars	in	millions)

Noninterest	income:

Fixed	income	(a)

Deposit	transactions	and	cash	management

Mortgage	banking	and	title	income

Brokerage,	management	fees	and	commissions

Card	and	digital	banking	fees

Trust	services	and	investment	management

Other	service	charges	and	fees
Securities	gains	(losses),	net	(b)

Purchase	accounting	gain

Other	income	(c)

					Total	noninterest	income

(Dollars	in	millions)

Noninterest	income:

Fixed	income	(a)

Deposit	transactions	and	cash	management

Mortgage	banking	and	title	income

Brokerage,	management	fees	and	commissions

Card	and	digital	banking	fees

Trust	services	and	investment	management

Other	service	charges	and	fees

Securities	gains	(losses),	net	(b)

Purchase	accounting	gain

Other	income	(c)

					Total	noninterest	income

(Dollars	in	millions)

Noninterest	income:

Fixed	income	(a)

Deposit	transactions	and	cash	management

Mortgage	banking	and	title	income

Brokerage,	management	fees	and	commissions

Card	and	digital	banking	fees

Trust	services	and	investment	management

Other	service	charges	and	fees

Other	income	(c)

$	

—	 $	

157	

—	

88	

67	

51	

23	
—	

—	

52	

406	 $	

12	

152	

—	

3	

—	

17	
—	

—	

7	

$	

438	 $	

597	 $	

—	 $	

6	

2	

—	

8	

—	

4	
13	

(1)	 	

9	

41	 $	

406	

175	

154	

88	

78	

51	

44	
13	

(1)	

68	

1,076	

Regional	Banking

Specialty	Banking

Corporate

Consolidated

December	31,	2020

$	

1	 $	

131	

—	

66	

50	

39	

18	

—	

—	

40	

422	 $	

11	

128	

—	

2	

—	

7	

—	

—	

6	

—	 $	

6	

1	

—	

8	

—	

1	

(6)	

533	

28	

423	

148	

129	

66	

60	

39	

26	

(6)	

533	

74	

$	

345	 $	

576	 $	

571	 $	

1,492	

Regional	Banking

Specialty	Banking

Corporate

Consolidated

December	31,	2019

$	

—	 $	

114	

—	

55	

41	

30	

16	

37	

278	 $	

1	 $	

11	

8	

—	

2	

—	

5	

11	

7	

2	

—	

6	

—	

—	

30	

279	

132	

10	

55	

49	

30	

21	

78	

					Total	noninterest	income

$	

293	 $	

315	 $	

46	 $	

654	

(a) 2021,	2020	and	2019,	include	$44million	,	$39	million	and	$34	million,	respectively,	of	underwriting,	portfolio	advisory,	and	other	noninterest	income	in	scope	of	ASC	606,	

"Revenue	From	Contracts	With	Customers."

(b) Represents	noninterest	income	excluded	from	the	scope	of	ASC	606.	Amount	is	presented	for	informational	purposes	to	reconcile	total	noninterest	income.
(c)

Includes	letter	of	credit	fees	and	insurance	commissions	in	scope	of	ASC	606.

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NOTE	21—VARIABLE	INTEREST	ENTITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Nonconsolidated	Variable	Interest	Entities

Low	Income	Housing	Tax	Credit	Partnerships

Through	designated	wholly-owned	subsidiaries,	First	
Horizon	Bank	makes	equity	investments	as	a	limited	
partner	in	various	partnerships	that	sponsor	affordable	
housing	projects	utilizing	the	LIHTC.	The	purpose	of	these	
investments	is	to	achieve	a	satisfactory	return	on	capital	
and	to	support	FHN’s	community	reinvestment	initiatives.	
LIHTC	partnerships	are	managed	by	unrelated	general	
partners	that	have	the	power	to	direct	the	activities	that	
most	significantly	affect	the	performance	of	the	
partnerships.	FHN	is	therefore	not	the	primary	beneficiary	
of	any	LIHTC	partnerships.	Accordingly,	FHN	does	not	
consolidate	these	VIEs	and	accounts	for	these	investments	
in	other	assets	on	the	Consolidated	Balance	Sheets.

FHN	accounts	for	all	qualifying	LIHTC	investments	under	
the	proportional	amortization	method.	Under	this	method	
an	entity	amortizes	the	initial	cost	of	the	investment	in	
proportion	to	the	tax	credits	and	other	tax	benefits	
received	and	recognizes	the	net	investment	performance	
as	a	component	of	income	tax	expense.	LIHTC	investments	
that	do	not	qualify	for	the	proportional	amortization	
method	are	accounted	for	using	the	equity	method.	
Expenses	associated	with	non-qualifying	LIHTC	
investments	were	not	material	during	2021,	2020,	and	
2019.	

The	following	table	summarizes	the	impact	to	income	tax	
expense	on	the	Consolidated	Statements	of	Income	for	
the	years	ended	December	31,	2021,	2020	and	2019	for	
LIHTC	investments	accounted	for	under	the	proportional	
amortization	method.

Table	8.21.2

LIHTC	IMPACTS	ON	TAX	EXPENSE

(Dollars	in	millions)

2021

2020

2019

Income	tax	expense	(benefit):

Amortization	of	qualifying	
LIHTC	investments

Low	income	housing	tax	
credits

Other	tax	benefits	related	to	
qualifying	LIHTC	
investments

$	

26	 $	

23	 $	

15	

(32)	

(22)	

(14)	

(7)	

(10)	

(6)	

Note 21—Variable Interest Entities

FHN	makes	equity	investments	in	various	entities	that	are	
considered	VIEs,	as	defined	by	GAAP.	A	VIE	typically	does	
not	have	sufficient	equity	at	risk	to	finance	its	activities	
without	additional	subordinated	financial	support	from	
other	parties.	The	Company’s	variable	interest	arises	from	
contractual,	ownership	or	other	monetary	interests	in	the	
entity,	which	change	with	fluctuations	in	the	fair	value	of	
the	entity's	net	assets.	FHN	consolidates	a	VIE	if	it	is	the	
primary	beneficiary	of	the	entity.	FHN	is	the	primary	
beneficiary	of	a	VIE	if	its	variable	interest	provides	it	with	
the	power	to	direct	the	activities	that	most	significantly	
impact	the	VIE	and	the	right	to	receive	benefits	(or	the	
obligation	to	absorb	losses)	that	could	potentially	be	
significant	to	the	VIE.	To	determine	whether	or	not	a	
variable	interest	held	could	potentially	be	significant	to	
the	VIE,	FHN	considers	both	qualitative	and	quantitative	
factors	regarding	the	nature,	size	and	form	of	its	
involvement	with	the	VIE.	FHN	assesses	whether	or	not	it	
is	the	primary	beneficiary	of	a	VIE	on	an	ongoing	basis.

Consolidated	Variable	Interest	Entities

FHN	has	established	certain	rabbi	trusts	related	to	
deferred	compensation	plans	offered	to	its	employees.	
FHN	contributes	employee	cash	compensation	deferrals	to	
the	trusts	and	directs	the	underlying	investments	made	by	
the	trusts.	The	assets	of	these	trusts	are	available	to	FHN’s	
creditors	only	in	the	event	that	FHN	becomes	insolvent.	
These	trusts	are	considered	VIEs	as	there	is	no	equity	at	
risk	in	the	trusts	since	FHN	provided	the	equity	interest	to	
its	employees	in	exchange	for	services	rendered.	FHN	is	
considered	the	primary	beneficiary	of	the	rabbi	trusts	as	it	
has	the	power	to	direct	the	activities	that	most	
significantly	impact	the	economic	performance	of	the	
rabbi	trusts	through	its	ability	to	direct	the	underlying	
investments	made	by	the	trusts.	Additionally,	FHN	could	
potentially	receive	benefits	or	absorb	losses	that	are	
significant	to	the	trusts	due	to	its	right	to	receive	any	asset	
values	in	excess	of	liability	payoffs	and	its	obligation	to	
fund	any	liabilities	to	employees	that	are	in	excess	of	a	
rabbi	trust’s	assets.

The	following	table	summarizes	the	carrying	value	of	
assets	and	liabilities	associated	with	rabbi	trusts	used	for	
deferred	compensation	plans	which	are	consolidated	by	
FHN	as	of	December	31,	2021	and	2020:

Table	8.21.1

(Dollars	in	millions)

Assets:

Other	assets

Liabilities:

Other	liabilities

CONSOLIDATED	VIEs 
December	31,	
2021

December	31,	
2020

$	

$	

205	 $	

179	 $	

195	

165	

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Table of Contents

NOTE	21—VARIABLE	INTEREST	ENTITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Other	Tax	Credit	Investments

Through	designated	subsidiaries,	First	Horizon	Bank	
periodically	makes	equity	investments	as	a	non-managing	
member	in	various	LLCs	that	sponsor	community	
development	projects	utilizing	the	NMTC.	First	Horizon	
Bank	also	makes	equity	investments	as	a	limited	partner	
or	non-managing	member	in	entities	that	receive	solar	
and	historic	tax	credits.	The	purpose	of	these	investments	
is	to	achieve	a	satisfactory	return	on	capital	and	to	
support	FHN’s	community	reinvestment	initiatives.	These	
entities	are	considered	VIEs	as	First	Horizon	Bank's	
subsidiaries	represent	the	holders	of	the	equity	
investment	at	risk,	but	do	not	have	the	ability	to	direct	the	
activities	that	most	significantly	affect	the	performance	of	
the	entities.	

Small	Issuer	Trust	Preferred	Holdings

First	Horizon	Bank	holds	variable	interests	in	trusts	which	
have	issued	mandatorily	redeemable	preferred	capital	
securities	(“trust	preferreds”)	for	smaller	banking	and	
insurance	enterprises.	First	Horizon	Bank	has	no	voting	
rights	for	the	trusts’	activities.	The	trusts’	only	assets	are	
junior	subordinated	debentures	of	the	issuing	enterprises.	
The	creditors	of	the	trusts	hold	no	recourse	to	the	assets	
of	First	Horizon	Bank.	Since	First	Horizon	Bank	is	solely	a	
holder	of	the	trusts’	securities,	it	has	no	rights	that	would	
give	it	the	power	to	direct	the	activities	that	most	
significantly	impact	the	trusts’	economic	performance	and	
thus	it	is	not	considered	the	primary	beneficiary	of	the	
trusts.	First	Horizon	Bank	has	no	contractual	requirements	
to	provide	financial	support	to	the	trusts.

On-Balance	Sheet	Trust	Preferred	Securitization

	In	2007,	First	Horizon	Bank	executed	a	securitization	of	
certain	small	issuer	trust	preferreds	for	which	the	
underlying	trust	meets	the	definition	of	a	VIE,	as	the	
holders	of	the	equity	investment	at	risk	do	not	have	the	
power	through	voting	rights,	or	similar	rights,	to	direct	the	
activities	that	most	significantly	impact	the	entity’s	
economic	performance.	Since	First	Horizon	Bank	did	not	
retain	servicing	or	other	decision-making	rights,	First	
Horizon	Bank	is	not	the	primary	beneficiary	as	it	does	not	
have	the	power	to	direct	the	activities	that	most	
significantly	impact	the	trust’s	economic	performance.	
Accordingly,	First	Horizon	Bank	has	accounted	for	the	
funds	received	through	the	securitization	as	a	term	
borrowing	in	its	Consolidated	Balance	Sheets.	First	
Horizon	Bank	has	no	contractual	requirements	to	provide	
financial	support	to	the	trust.

Holdings	in	Agency	Mortgage-Backed	Securities

FHN	holds	securities	issued	by	various	Agency	
securitization	trusts.	Based	on	their	restrictive	nature,	the	
trusts	meet	the	definition	of	a	VIE	since	the	holders	of	the	

equity	investments	at	risk	do	not	have	the	power	through	
voting	rights,	or	similar	rights,	to	direct	the	activities	that	
most	significantly	impact	the	entities’	economic	
performance.	FHN	could	potentially	receive	benefits	or	
absorb	losses	that	are	significant	to	the	trusts	based	on	
the	nature	of	the	trusts’	activities	and	the	size	of	FHN’s	
holdings.	However,	FHN	is	solely	a	holder	of	the	trusts’	
securities	and	does	not	have	the	power	to	direct	the	
activities	that	most	significantly	impact	the	trusts’	
economic	performance,	and	is	not	considered	the	primary	
beneficiary	of	the	trusts.	FHN	has	no	contractual	
requirements	to	provide	financial	support	to	the	trusts.

Commercial	Loan	Troubled	Debt	Restructurings

For	certain	troubled	commercial	loans,	First	Horizon	Bank	
restructures	the	terms	of	the	borrower’s	debt	in	an	effort	
to	increase	the	probability	of	receipt	of	amounts	
contractually	due.	Following	a	troubled	debt	restructuring,	
the	borrower	entity	typically	meets	the	definition	of	a	VIE	
as	the	initial	determination	of	whether	an	entity	is	a	VIE	
must	be	reconsidered	as	events	have	proven	that	the	
entity’s	equity	is	not	sufficient	to	permit	it	to	finance	its	
activities	without	additional	subordinated	financial	
support	or	a	restructuring	of	the	terms	of	its	financing.	As	
First	Horizon	Bank	does	not	have	the	power	to	direct	the	
activities	that	most	significantly	impact	such	troubled	
commercial	borrowers’	operations,	it	is	not	considered	the	
primary	beneficiary	even	in	situations	where,	based	on	the	
size	of	the	financing	provided,	First	Horizon	Bank	is	
exposed	to	potentially	significant	benefits	and	losses	of	
the	borrowing	entity.	First	Horizon	Bank	has	no	
contractual	requirements	to	provide	financial	support	to	
the	borrowing	entities	beyond	certain	funding	
commitments	established	upon	restructuring	of	the	terms	
of	the	debt	that	allows	for	preparation	of	the	underlying	
collateral	for	sale.

Proprietary	Trust	Preferred	Issuances

In	conjunction	with	its	acquisitions,	FHN	acquired	junior	
subordinated	debt	underlying	multiple	issuances	of	trust	
preferred	debt.	All	of	the	trusts	are	considered	VIEs	
because	the	ownership	interests	from	the	capital	
contributions	to	these	trusts	are	not	considered	“at	risk”	
in	evaluating	whether	the	holders	of	the	equity	
investments	at	risk	in	the	trusts	have	the	ability	to	direct	
the	activities	that	most	significantly	impact	the	entities’	
economic	performance.	Thus,	FHN	cannot	be	the	trusts’	
primary	beneficiary	because	its	ownership	interests	in	the	
trusts	are	not	considered	variable	interests	as	they	are	not	
considered	“at	risk”.	Consequently,	none	of	the	trusts	are	
consolidated	by	FHN.

The	following	tables	summarize	FHN’s	nonconsolidated	
VIEs	as	of	December	31,	2021	and	2020:

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	21—VARIABLE	INTEREST	ENTITIES

NONCONSOLIDATED	VIEs	AT	YE	2021

Table of Contents

Table	8.21.3

(Dollars	in	millions)

Type:

Low	income	housing	partnerships

Other	tax	credit	investments	(b)

Small	issuer	trust	preferred	holdings	(c)

On-balance	sheet	trust	preferred	securitization

Holdings	of	agency	mortgage-backed	securities	(c)

Commercial	loan	troubled	debt	restructurings	(f)

Proprietary	trust	preferred	issuances	(g)

Maximum
Loss	Exposure

Liability
Recognized

Classification

$	

382	 $	

129	

(a)

77	

195	

27	

8,550	

98	

—	

56	

—	

87	

—	

—	

Other	assets

Loans	and	leases

(d)

(e)

Loans	and	leases

167	

Term	borrowings

(a)	 Maximum	loss	exposure	represents	$253	million	of	current	investments	and	$129	million	of	accrued	contractual	funding	commitments.	Accrued	funding	
commitments	represent	unconditional	contractual	obligations	for	future	funding	events,	and	are	recognized	in	other	liabilities.	FHN	currently	expects	to	
be	required	to	fund	these	accrued	commitments	by	the	end	of	2024.

(b)	 Maximum	loss	exposure	represents	the	value	of	current	investments.	
(c)	 Maximum	loss	exposure	represents	the	value	of	current	investments.	A	liability	is	not	recognized	as	FHN	is	solely	a	holder	of	the	trusts’	securities.
(d)	 Includes	$112	million	classified	as	loans	and	leases,	and	$2	million	classified	as	trading	securities	which	are	offset	by	$87	million	classified	as	term	

borrowings.

(e)	 Includes	$526	million	classified	as	trading	securities,	$712	million	classified	as	securities	held	to	maturity	and	$7.3	billion	classified	as	securities	available	

for	sale.

(f)	 Maximum	loss	exposure	represents	$94	million	of	current	receivables	and	$4	million	of	contractual	funding	commitments	on	loans	related	to	commercial	

borrowers	involved	in	a	troubled	debt	restructuring.
(g)	 No	exposure	to	loss	due	to	nature	of	FHN's	involvement.	

NONCONSOLIDATED	VIEs	AT	YE	2020

Table	8.21.4

(Dollars	in	millions)

Type:

Low	income	housing	partnerships

Other	tax	credit	investments	(b)	

Small	issuer	trust	preferred	holdings	(c)

On-balance	sheet	trust	preferred	securitization

Holdings	of	agency	mortgage-backed	securities	(c)

Commercial	loan	troubled	debt	restructurings	(f)

Proprietary	trust	preferred	issuances	(g)

Maximum
Loss	Exposure

Liability
Recognized

Classification

$	

338	 $	

132	

(a)

64	

210	

32	

7,063	

186	

—	

42	

—	

82	

—	

—	

Other	assets

Loans	and	leases

(d)

(e)

Loans	and	leases

287	

Term	borrowings

(a) Maximum	loss	exposure	represents	$206	million	of	current	investments	and	$132	million	of	accrued	contractual	funding	commitments.	Accrued	funding	
commitments	represent	unconditional	contractual	obligations	for	future	funding	events,	and	are	recognized	in	other	liabilities.	FHN	currently	expects	to	
be	required	to	fund	these	accrued	commitments	by	the	end	of	2024.	
(b) Maximum	loss	exposure	represents	the	value	of	current	investments.	
(c) Maximum	loss	exposure	represents	the	value	of	current	investments.	A	liability	is	not	recognized	as	FHN	is	solely	a	holder	of	the	trusts’	securities.
(d) Includes	$112	million	classified	as	loans	and	leases	and	$2	million	classified	as	trading	securities,	which	are	offset	by	$82	million	classified	as	term	

borrowings.

(e) Includes	$845	million	classified	as	trading	securities	and	$6.2	billion	classified	as	securities	available	for	sale.
(f) Maximum	loss	exposure	represents	$176	million	of	current	receivables	and	$10	million	of	contractual	funding	commitments	on	loans	related	to	

commercial	borrowers	involved	in	a	troubled	debt	restructuring.

(g) No	exposure	to	loss	due	to	nature	of	FHN's	involvement.

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Table of Contents

NOTE	22—DERIVATIVES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 22—Derivatives

In	the	normal	course	of	business,	FHN	utilizes	various	
financial	instruments	(including	derivative	contracts	and	
credit-related	agreements)	through	its	fixed	income	and	
risk	management	operations,	as	part	of	its	risk	
management	strategy	and	as	a	means	to	meet	clients’	
needs.	Derivative	instruments	are	subject	to	credit	and	
market	risks	in	excess	of	the	amount	recorded	on	the	
balance	sheet	as	required	by	GAAP.	The	contractual	or	
notional	amounts	of	these	financial	instruments	do	not	
necessarily	represent	the	amount	of	credit	or	market	risk.	
However,	they	can	be	used	to	measure	the	extent	of	
involvement	in	various	types	of	financial	instruments.	
Controls	and	monitoring	procedures	for	these	instruments	
have	been	established	and	are	routinely	reevaluated.	The	
ALCO	controls,	coordinates,	and	monitors	the	usage	and	
effectiveness	of	these	financial	instruments.

Credit	risk	represents	the	potential	loss	that	may	occur	if	a	
party	to	a	transaction	fails	to	perform	according	to	the	
terms	of	the	contract.	The	measure	of	credit	exposure	is	
the	replacement	cost	of	contracts	with	a	positive	fair	
value.	FHN	manages	credit	risk	by	entering	into	financial	
instrument	transactions	through	national	exchanges,	
primary	dealers	or	approved	counterparties,	and	by	using	
mutual	margining	and	master	netting	agreements	
whenever	possible	to	limit	potential	exposure.	FHN	also	
maintains	collateral	posting	requirements	with	certain	
counterparties	to	limit	credit	risk.	Daily	margin	posted	or	
received	with	central	clearinghouses	is	considered	a	legal	
settlement	of	the	related	derivative	contracts	which	
results	in	a	net	presentation	for	each	contract	in	the	
Consolidated	Balance	Sheets.	Treatment	of	daily	margin	as	
a	settlement	has	no	effect	on	hedge	accounting	or	gains/
losses	for	the	applicable	derivative	contracts.	On	
December	31,	2021	and	2020,	respectively,	FHN	had	$181	
million	and	$280	million	of	cash	receivables	and	$102	
million	and	$166	million	of	cash	payables	related	to	
collateral	posting	under	master	netting	arrangements,	
inclusive	of	collateral	posted	related	to	contracts	with	
adjustable	collateral	posting	thresholds	and	over-
collateralized	positions,	with	derivative	counterparties.	
With	exchange-traded	contracts,	the	credit	risk	is	limited	
to	the	clearinghouse	used.	For	non-exchange	traded	
instruments,	credit	risk	may	occur	when	there	is	a	gain	in	
the	fair	value	of	the	financial	instrument	and	the	
counterparty	fails	to	perform	according	to	the	terms	of	
the	contract	and/or	when	the	collateral	proves	to	be	of	
insufficient	value.	See	additional	discussion	regarding	
master	netting	agreements	and	collateral	posting	
requirements	later	in	this	note	under	the	heading	“Master	
Netting	and	Similar	Agreements.”	Market	risk	represents	
the	potential	loss	due	to	the	decrease	in	the	value	of	a	
financial	instrument	caused	primarily	by	changes	in	
interest	rates	or	the	prices	of	debt	instruments.	FHN	
manages	market	risk	by	establishing	and	monitoring	limits	
on	the	types	and	degree	of	risk	that	may	be	undertaken.	

FHN	continually	measures	this	risk	through	the	use	of	
models	that	measure	value-at-risk	and	earnings-at-risk.

Derivative	Instruments

FHN	enters	into	various	derivative	contracts	both	to	
facilitate	client	transactions	and	as	a	risk	management	
tool.	Where	contracts	have	been	created	for	clients,	FHN	
enters	into	upstream	transactions	with	dealers	to	offset	its	
risk	exposure.	Contracts	with	dealers	that	require	central	
clearing	are	novated	to	a	clearing	agent	who	becomes	
FHN’s	counterparty.	Derivatives	are	also	used	as	a	risk	
management	tool	to	hedge	FHN’s	exposure	to	changes	in	
interest	rates	or	other	defined	market	risks.

Forward	contracts	are	over-the-counter	contracts	where	
two	parties	agree	to	purchase	and	sell	a	specific	quantity	
of	a	financial	instrument	at	a	specified	price,	with	delivery	
or	settlement	at	a	specified	date.	Futures	contracts	are	
exchange-traded	contracts	where	two	parties	agree	to	
purchase	and	sell	a	specific	quantity	of	a	financial	
instrument	at	a	specified	price,	with	delivery	or	settlement	
at	a	specified	date.	Interest	rate	option	contracts	give	the	
purchaser	the	right,	but	not	the	obligation,	to	buy	or	sell	a	
specified	quantity	of	a	financial	instrument,	at	a	specified	
price,	during	a	specified	period	of	time.	Caps	and	floors	
are	options	that	are	linked	to	a	notional	principal	amount	
and	an	underlying	indexed	interest	rate.	Interest	rate	
swaps	involve	the	exchange	of	interest	payments	at	
specified	intervals	between	two	parties	without	the	
exchange	of	any	underlying	principal.	Swaptions	are	
options	on	interest	rate	swaps	that	give	the	purchaser	the	
right,	but	not	the	obligation,	to	enter	into	an	interest	rate	
swap	agreement	during	a	specified	period	of	time.

Trading	Activities

FHNF	trades	U.S.	Treasury,	U.S.	Agency,	government-
guaranteed	loan,	mortgage-backed,	corporate	and	
municipal	fixed	income	securities,	and	other	securities	for	
distribution	to	clients.	When	these	securities	settle	on	a	
delayed	basis,	they	are	considered	forward	contracts.	
FHNF	also	enters	into	interest	rate	contracts,	including	
caps,	swaps,	and	floors	for	its	clients.	In	addition,	FHNF	
enters	into	futures	and	option	contracts	to	economically	
hedge	interest	rate	risk	associated	with	a	portion	of	its	
securities	inventory.	These	transactions	are	measured	at	
fair	value,	with	changes	in	fair	value	recognized	in	
noninterest	income.	Related	assets	and	liabilities	are	
recorded	on	the	Consolidated	Balance	Sheets	as	derivative	
assets	and	derivative	liabilities	within	other	assets	and	
other	liabilities.	The	FHNF	Risk	Committee	and	the	Credit	
Risk	Management	Committee	collaborate	to	mitigate	
credit	risk	related	to	these	transactions.	Credit	risk	is	
controlled	through	credit	approvals,	risk	control	limits,	
and	ongoing	monitoring	procedures.	Total	trading	
revenues	were	$360	million,	$371	million	and	$228	million	
for	the	years	ended	December	31,	2021,	2020	and	2019,	
respectively.	Trading	revenues	are	inclusive	of	both	

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Table of Contents

NOTE	22—DERIVATIVES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

derivative	and	non-derivative	financial	instruments,	and	
are	included	in	fixed	income	on	the	Consolidated	
Statements	of	Income.

The	following	tables	summarize	derivatives	associated	
with	FHNF's	trading	activities	as	of	December	31,	2021	
and	2020:

Table	8.22.1a-b

DERIVATIVES	ASSOCIATED	WITH	TRADING

(Dollars	in	millions)
Customer	interest	rate	contracts

Offsetting	upstream	interest	rate	contracts

Option	contracts	purchased

Forwards	and	futures	purchased

Forwards	and	futures	sold

(Dollars	in	millions)
Customer	interest	rate	contracts

Offsetting	upstream	interest	rate	contracts
Forwards	and	futures	purchased

Forwards	and	futures	sold

Interest	Rate	Risk	Management

FHN’s	ALCO	focuses	on	managing	market	risk	by	
controlling	and	limiting	earnings	volatility	attributable	to	
changes	in	interest	rates.	Interest	rate	risk	exists	to	the	
extent	that	interest-earning	assets	and	interest-bearing	
liabilities	have	different	maturity	or	repricing	
characteristics.	FHN	uses	derivatives,	primarily	swaps,	that	
are	designed	to	moderate	the	impact	on	earnings	as	
interest	rates	change.	Interest	paid	or	received	for	swaps	
utilized	by	FHN	to	hedge	the	fair	value	of	long	term	debt	is	
recognized	as	an	adjustment	of	the	interest	expense	of	
the	liabilities	whose	risk	is	being	managed.	FHN’s	interest	
rate	risk	management	policy	is	to	use	derivatives	to	hedge	
interest	rate	risk	or	market	value	of	assets	or	liabilities,	
not	to	speculate.	In	addition,	FHN	has	entered	into	certain	
interest	rate	swaps	and	caps	as	a	part	of	a	product	
offering	to	commercial	clients	that	includes	customer	

Notional

December	31,	2021
Assets

Liabilities

$	

3,587	 $	

84	 $	

3,587	

13	

4,430	

5,044	

4	

—	

2	

10	

Notional

December	31,	2020
Assets

Liabilities

$	

3,950	 $	

207	 $	

3,950	

10,795	

11,633	

2	

62	

1	

41	

8	

—	

9	

2	

7	

17	

—	

65	

derivatives	paired	with	upstream	offsetting	market	
instruments	that,	when	completed,	are	designed	to	
mitigate	interest	rate	risk.	These	contracts	do	not	qualify	
for	hedge	accounting	and	are	measured	at	fair	value	with	
gains	or	losses	included	in	current	earnings	in	noninterest	
expense	on	the	Consolidated	Statements	of	Income.

FHN	had	designated	a	derivative	transaction	in	a	hedging	
strategy	to	manage	interest	rate	risk	on	$500	million	of	
senior	debt	prior	to	its	maturity	in	December	2020.	This	
transaction	qualified	for	hedge	accounting	using	the	long-
haul	method.	FHN	early	redeemed	the	$500	million	senior	
debt	in	November	2020.	

The	following	tables	summarize	FHN’s	derivatives	
associated	with	interest	rate	risk	management	activities	as	
of	December	31,	2021	and	2020:

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Table of Contents

Table	8.22.2a-b

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	22—DERIVATIVES

DERIVATIVES	ASSOCIATED	WITH	INTEREST	RATE	RISK	MANAGEMENT

(Dollars	in	millions)
Customer	Interest	Rate	Contracts	Hedging	
Hedging	Instruments	and	Hedged	Items:	

Customer	interest	rate	contracts

Offsetting	upstream	interest	rate	contracts

(Dollars	in	millions)
Customer	Interest	Rate	Contracts	Hedging
Hedging	Instruments	and	Hedged	Items:	

Customer	interest	rate	contracts

Offsetting	upstream	interest	rate	contracts

Notional

December	31,	2021
Assets

Liabilities

$	

8,037	 $	

202	 $	

8,037	

4	

Notional

December	31,	2020
Assets

Liabilities

$	

6,868	 $	

436	 $	

6,868	

5	

29	

15	

1	

35	

The	following	table	summarizes	gains	(losses)	on	FHN’s	derivatives	associated	with	interest	rate	risk	management	activities	for	
the	years	ended	December	31,	2021,	2020,	and	2019:

Table	8.22.3

DERIVATIVE	GAINS	(LOSSES)	ASSOCIATED	WITH	INTEREST	RATE	RISK	MANAGEMENT

(Dollars	in	millions)
Customer	Interest	Rate	Contracts	Hedging
Hedging	Instruments	and	Hedged	Items:

Customer	interest	rate	contracts	(a)

Offsetting	upstream	interest	rate	contracts	(a)

Debt	Hedging
Hedging	Instruments:

Interest	rate	swaps	(b)

Hedged	Items:

Term	borrowings	(a)	(c)

2021
Gains	(Losses)

Year	Ended	December	31,
2020
Gains	(Losses)

2019
Gains	(Losses)

$	

$	

(268)	 $	
268	

357	 $	

(357)	

—	 $	

2	 $	

—	

(2)	

92	

(92)	

13	

(13)	

(a) Gains	(losses)	included	in	other	expense	within	the	Consolidated	Statements	of	Income.
(b) Gains	(losses)	included	in	interest	expense.
(c) Represents	gains	and	losses	attributable	to	changes	in	fair	value	due	to	interest	rate	risk	as	designated	in	ASC	815-20	hedging	relationships.

Cash	Flow	Hedges

Prior	to	2021,	FHN	had	pay	floating,	receive	fixed	interest	
rate	swaps	designed	to	manage	its	exposure	to	the	
variability	in	cash	flows	related	to	interest	payments	on	
debt	instruments,	which	primarily	consisted	of	held-to-
maturity	trust	preferred	loans.	In	conjunction	with	the	
IBKC	merger,	FHN	acquired	interest	rate	contracts	(floors	
and	collars)	which	have	been	re-designated	as	cash	flow	
hedges.	The	debt	instruments	primarily	consist	of	held-to-
maturity	commercial	loans	that	have	variable	interest	
payments	based	on	1-month	LIBOR.

In	a	cash	flow	hedge,	the	entire	change	in	the	fair	value	of	
the	interest	rate	swap	included	in	the	assessment	of	
hedge	effectiveness	is	initially	recorded	in	OCI	and	is	
subsequently	reclassified	from	OCI	to	current	period	
earnings	(interest	income	or	interest	expense)	in	the	same	
period	that	the	hedged	item	affects	earnings.

The	following	tables	summarize	FHN’s	derivative	activities	
associated	with	cash	flow	hedges	as	of	December	31,	2021	
and	2020:

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	22—DERIVATIVES

DERIVATIVES	ASSOCIATED	WITH	CASH	FLOW	HEDGES

Notional

December	31,	2021
Assets

Liabilities

Table of Contents

Table	8.22.4a-b

(Dollars	in	millions)

Cash	Flow	Hedges	
Hedging	Instruments:	

Interest	rate	contracts

Hedged	Items:

(Dollars	in	millions)

Cash	Flow	Hedges
Hedging	Instruments:	

Interest	rate	contracts

Hedged	Items:

Variability	in	cash	flows	related	to	debt	instruments	(primarily	loans)

N/A $	

1,100	

$	

1,100	 $	

13	 $	

Notional

December	31,	2020
Assets

Liabilities

$	

1,250	 $	

32	 $	

—	

N/A

—	

N/A

Variability	in	cash	flows	related	to	debt	instruments	(primarily	loans)

N/A $	

1,250	

The	following	table	summarizes	gains	(losses)	on	FHN’s	derivatives	associated	with	cash	flow	hedges	for	the	years	ended	
December	31,	2021,	2020,	and	2019:

Table	8.22.5

DERIVATIVE	GAINS	(LOSSES)	ASSOCIATED	WITH	CASH	FLOW	HEDGES

(Dollars	in	millions)
Cash	Flow	Hedges
Hedging	Instruments:

Interest	rate	contracts	(a)	

Gain	(loss)	recognized	in	other	comprehensive	income	(loss)

Gain	(loss)	reclassified	from	AOCI	into	interest	income

2021
Gains	(Losses)

Year	Ended	December	31,
2020
Gains	(Losses)

2019
Gains	(Losses)

$	

29	 $	

3	 $	

(3)	

(7)	

15	

(6)	

21	

11	

4	

(a) Approximately	$15	million	of	pre-tax	gains	are	expected	to	be	reclassified	into	earnings	in	the	next	twelve	months.

Other	Derivatives

As	part	of	the	merger	with	IBKC,	FHN	acquired	mortgage	
banking	operations	that	include	the	origination	and	sale	of	
loans	into	the	secondary	market.	As	part	of	the	origination	
of	loans,	FHN	enters	into	interest	rate	lock	commitments	
with	borrowers.	

Additionally,	FHN	enters	into	forward	sales	contracts	with	
buyers	for	delivery	of	loans	at	a	future	date.	Both	of	these	
contracts	qualify	as	freestanding	derivatives	and	are	
recognized	at	fair	value	through	earnings.	The	notional	
and	fair	values	of	these	contracts	are	presented	in	the	
table	below.	Balances	and	activity	for	periods	prior	to	the	
IBKC	merger	were	not	significant.

Table	8.22.6a-b

DERIVATIVES	ASSOCIATED	WITH	MORTGAGE	BANKING	HEDGES

(Dollars	in	millions)

Mortgage	Banking	Hedges

Option	contracts	written

Forward	contracts	written

December	31,	2021

Notional

Assets

Liabilities

$	

241	 $	
404  

4	 $	

— 

—	
— 

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Table of Contents

NOTE	22—DERIVATIVES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(Dollars	in	millions)

Mortgage	Banking	Hedges
Option	contracts	written

Forward	contracts	written

December	31,	2020

Notional

Assets

Liabilities

$	

667	 $	

725	

20	 $	

—	

—	

6	

The	following	table	summarizes	gains	(losses)	on	FHN's	derivatives	associated	with	mortgage	banking	activities	for	the	years	
ended	December	31,	2021	and	2020:

Table	8.22.7

DERIVATIVE	GAINS	(LOSSES)	ASSOCIATED	WITH	MORTGAGE	BANKING	HEDGES

(Dollars	in	millions)

Mortgage	Banking	Hedges
Option	contracts	written

Forward	contracts	written

In	conjunction	with	pre-2020	sales	of	Visa	Class	B	shares,	
FHN	entered	into	derivative	transactions	whereby	FHN	
will	make	or	receive	cash	payments	whenever	the	
conversion	ratio	of	the	Visa	Class	B	shares	into	Visa	Class	A	
shares	is	adjusted.	As	of	December	31,	2021	and	
December	31,	2020,	the	derivative	liabilities	associated	
with	the	sales	of	Visa	Class	B	shares	were	$23	million	and	
$13	million,	respectively.	For	the	year	ended	December	
31,	2021,	FHN	recognized	$19	million	in	derivative	
valuation	adjustments	related	to	prior	sales	of	Visa	Class	B	
shares.	These	derivative	adjustments	were	insignificant	for	
the	year	ended	December	31,	2020.	See	Note	24	-	Fair	
Value	of	Assets	and	Liabilities	for	discussion	of	the	
valuation	inputs	and	processes	for	these	Visa-related	
derivatives.

FHN	utilizes	cross	currency	swaps	and	cross	currency	
interest	rate	swaps	to	economically	hedge	its	exposure	to	
foreign	currency	risk	and	interest	rate	risk	associated	with	
non-U.S.	dollar	denominated	loans.	As	of	December	31,	
2021	and	2020,	these	loans	were	valued	at	$7	million	and	
$12	million,	respectively.	The	balance	sheet	amount	and	
the	gains/losses	associated	with	these	derivatives	were	
not	significant.

Related	to	its	loan	participation/syndication	activities,	FHN	
enters	into	risk	participation	agreements,	under	which	it	
assumes	exposure	for,	or	receives	indemnification	for,	
borrowers’	performance	on	underlying	interest	rate	
derivative	contracts.	FHN’s	counterparties	in	these	
contracts	are	other	lending	institutions	involved	in	the	
loan	participation/syndication	arrangements	for	which	the	
underlying	interest	rate	derivative	contract	is	intended	to	
hedge	interest	rate	risk	for	the	borrower.	FHN	will	make	
(other	institution	is	the	lead	bank)	or	receive	(FHN	is	the	
lead	bank)	payments	for	risk	participations	if	the	borrower	
defaults	on	its	obligation	to	perform	under	the	terms	of	its	
interest	rate	derivative	agreement	with	the	lead	bank	in	

	Year	Ended
December	31,

2021
Gains	(Losses)

2020
Gains	(Losses)

$	

15	 $	
11	

15	

(37)	

the	participation.	As	of	December	31,	2021	and	2020,	the	
notional	values	of	FHN’s	risk	participations	were	$257	
million	and	$233	million	of	derivative	assets	and	$500	
million	and	$464	million	of	derivative	liabilities,	
respectively.	The	notional	value	for	risk	participation/
syndication	agreements	is	consistent	with	the	percentage	
of	participation	in	the	lending	arrangement.	FHN’s	
maximum	exposure	or	benefit	in	the	risk	participation	
agreements	is	contingent	on	the	fair	value	of	the	
underlying	interest	rate	derivative	contracts	for	which	the	
borrower	is	in	a	liability	position	at	the	time	of	default.	
FHN	monitors	the	credit	risk	associated	with	the	
borrowers	to	which	the	risk	participations	relate	through	
the	same	credit	risk	assessment	process	utilized	for	
establishing	credit	loss	estimates	for	its	loan	portfolio.	
These	credit	risk	estimates	are	included	in	the	
determination	of	fair	value	for	the	risk	participations.	
Assuming	all	underlying	third	party	customers	referenced	
in	the	swap	contracts	defaulted	at	December	31,	2021	and	
2020,	the	exposure	from	these	agreements	would	not	be	
material	based	on	the	fair	value	of	the	underlying	swaps.

In	conjunction	with	the	IBKC	merger,	FHN	obtained	certain	
certificates	of	deposit	with	the	rate	of	return	based	on	an	
equity	index	which	is	considered	an	embedded	derivative	
as	a	written	option	that	must	be	separately	recognized.	
The	risks	of	the	written	option	are	offset	by	purchasing	an	
option	with	terms	that	mirror	the	written	option,	which	is	
also	carried	at	fair	value	on	the	Company’s	Consolidated	
Balance	Sheets.	As	of	December	31,	2021	and	2020,	FHN	
had	recognized	$1	million	of	both	assets	and	liabilities	
associated	with	these	contracts.

Master	Netting	and	Similar	Agreements

FHN	uses	master	netting	agreements,	mutual	margining	
agreements	and	collateral	posting	requirements	to	
minimize	credit	risk	on	derivative	contracts.	Master	
netting	and	similar	agreements	are	used	when	

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NOTE	22—DERIVATIVES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

counterparties	have	multiple	derivatives	contracts	that	
allow	for	a	“right	of	setoff,”	meaning	that	a	counterparty	
may	net	offsetting	positions	and	collateral	with	the	same	
counterparty	under	the	contract	to	determine	a	net	
receivable	or	payable.	The	following	discussion	provides	
an	overview	of	these	arrangements	which	may	vary	due	to	
the	derivative	type	and	market	in	which	a	derivative	
transaction	is	executed.

Interest	rate	derivatives	are	subject	to	agreements	
consistent	with	standard	agreement	forms	of	the	ISDA.	
Currently,	all	interest	rate	derivative	contracts	are	entered	
into	as	over-the-counter	transactions	and	collateral	
posting	requirements	are	based	on	the	net	asset	or	
liability	position	with	each	respective	counterparty.	For	
contracts	that	require	central	clearing,	novation	to	a	
counterparty	with	access	to	a	clearinghouse	occurs	and	
initial	margin	is	posted.	Cash	margin	received	(posted)	
that	is	considered	settlements	for	the	derivative	contracts	
is	included	in	the	respective	derivative	asset	(liability)	
value.	Cash	margin	that	is	considered	collateral	received	
(posted)	for	interest	rate	derivatives	is	recognized	as	a	
liability	(asset)	on	FHN’s	Consolidated	Balance	Sheet.

Interest	rate	derivatives	with	clients	that	are	smaller	
financial	institutions	typically	require	posting	of	collateral	
by	the	counterparty	to	FHN.	This	collateral	is	subject	to	a	
threshold	with	daily	adjustments	based	upon	changes	in	
the	level	or	fair	value	of	the	derivative	position.	Positions	
and	related	collateral	can	be	netted	in	the	event	of	
default.	Collateral	pledged	by	a	counterparty	is	typically	
cash	or	securities.	The	securities	pledged	as	collateral	are	
not	recognized	within	FHN’s	Consolidated	Balance	Sheets.	
Interest	rate	derivatives	associated	with	lending	
arrangements	share	the	collateral	with	the	related	loan(s).	
The	derivative	and	loan	positions	may	be	netted	in	the	
event	of	default.	For	disclosure	purposes,	the	entire	
collateral	amount	is	allocated	to	the	loan.

Interest	rate	derivatives	with	larger	financial	institutions	
entered	into	prior	to	required	central	clearing	typically	
contain	provisions	whereby	the	collateral	posting	
thresholds	under	the	agreements	adjust	based	on	the	
credit	ratings	of	both	counterparties.	If	the	credit	rating	of	
FHN	and/or	First	Horizon	Bank	is	lowered,	FHN	could	be	
required	to	post	additional	collateral	with	the	
counterparties.	Conversely,	if	the	credit	rating	of	FHN	and/
or	First	Horizon	Bank	is	increased,	FHN	could	have	
collateral	released	and	be	required	to	post	less	collateral	
in	the	future.	Also,	if	a	counterparty’s	credit	ratings	were	
to	decrease,	FHN	and/or	First	Horizon	Bank	could	require	
the	posting	of	additional	collateral;	whereas	if	a	
counterparty’s	credit	ratings	were	to	increase,	the	
counterparty	could	require	the	release	of	excess	
collateral.	Collateral	for	these	arrangements	is	adjusted	
daily	based	on	changes	in	the	net	fair	value	position	with	
each	counterparty.

The	net	fair	value,	determined	by	individual	counterparty,	
of	all	derivative	instruments	with	adjustable	collateral	
posting	thresholds	was	$67	million	of	assets	and	$26	
million	of	liabilities	on	December	31,	2021,	and	$200	
million	of	assets	and	$5	million	of	liabilities	on	
December	31,	2020.	As	of	December	31,	2021	and	2020,	
FHN	had	received	collateral	of	$205	million	and	$320	
million	and	posted	collateral	of	$14	million	and	$34	
million,	respectively,	in	the	normal	course	of	business	
related	to	these	agreements.

Certain	agreements	entered	into	prior	to	required	central	
clearing	also	contain	accelerated	termination	provisions,	
inclusive	of	the	right	of	offset,	if	a	counterparty’s	credit	
rating	falls	below	a	specified	level.	If	a	counterparty’s	debt	
rating	(including	FHN’s	and	First	Horizon	Bank's)	were	to	
fall	below	these	minimums,	these	provisions	would	be	
triggered,	and	the	counterparties	could	terminate	the	
agreements	and	require	immediate	settlement	of	all	
derivative	contracts	under	the	agreements.	The	net	fair	
value,	determined	by	individual	counterparty,	of	all	
interest	rate	derivative	instruments	with	credit-risk-
related	contingent	accelerated	termination	provisions	was	
$74	million	of	assets	and	$30	million	of	liabilities	on	
December	31,	2021,	and	$216	million	of	assets	and	$17	
million	of	liabilities	on	December	31,	2020.	As	of	
December	31,	2021	and	2020,	FHN	had	received	collateral	
of	$213	million	and	$343	million	and	posted	collateral	of	
$18	million	and	$53	million,	respectively,	in	the	normal	
course	of	business	related	to	these	contracts.

FHNF	buys	and	sells	various	types	of	securities	for	its	
clients.	When	these	securities	settle	on	a	delayed	basis,	
they	are	considered	forward	contracts,	and	are	generally	
not	subject	to	master	netting	agreements.	For	futures	and	
options,	FHN	transacts	through	a	third	party,	and	the	
transactions	are	subject	to	margin	and	collateral	
maintenance	requirements.	In	the	event	of	default,	open	
positions	can	be	offset	along	with	the	associated	
collateral.

For	this	disclosure,	FHN	considers	the	impact	of	master	
netting	and	other	similar	agreements	which	allow	FHN	to	
settle	all	contracts	with	a	single	counterparty	on	a	net	
basis	and	to	offset	the	net	derivative	asset	or	liability	
position	with	the	related	securities	and	cash	collateral.	
The	application	of	the	collateral	cannot	reduce	the	net	
derivative	asset	or	liability	position	below	zero,	and	
therefore	any	excess	collateral	is	not	reflected	in	the	
following	tables.

The	following	table	provides	details	of	derivative	assets	
and	collateral	received	as	presented	on	the	Consolidated	
Balance	Sheets	as	of	December	31,	2021	and	2020:

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Table of Contents

Table	8.22.8

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	22—DERIVATIVES

DERIVATIVE	ASSETS	&	COLLATERAL	RECEIVED

(Dollars	in	millions)
Derivative	assets:

December	31,	2021
Interest	rate	derivative	
contracts
Forward	contracts

December	31,	2020

Interest	rate	derivative	
contracts
Forward	contracts

Gross	amounts
of	recognized
assets

Gross	amounts
offset	in	the
Balance	Sheets

Net	amounts	of
assets	presented
in	the	Balance	
Sheets	(a)

Derivative	
liabilities
available	for
offset

Collateral
received

Net	amount

Gross	amounts	not	offset	in	
the	Balance	Sheets

$	

$	

$	

$	

311	 $	

12	

323	 $	

702	 $	

63	

765	 $	

—	 $	

—	

—	 $	

—	 $	

—	

—	 $	

311	 $	

(32)	 $	

(181)	 $	

12	

(4)	 	

(3)	 	

323	 $	

(36)	 $	

(184)	 $	

702	 $	

(7)	 $	

(327)	 $	

63	

(14)	

(20)	 	

765	 $	

(21)	 $	

(347)	 $	

98	

5	

103	

368	

29	

397	

(a) Included	in	other	assets	on	the	Consolidated	Balance	Sheets.	As	of	December	31,	2021	and	2020,	$2	million	and	$4	million,	respectively,	of	derivative	

assets	have	been	excluded	from	these	tables	because	they	are	generally	not	subject	to	master	netting	or	similar	agreements.

The	following	table	provides	details	of	derivative	liabilities	and	collateral	pledged	as	presented	on	the	Consolidated	Balance	
Sheets	as	of	December	31,	2021	and	2020:

Table	8.22.9

DERIVATIVE	LIABILITIES	&	COLLATERAL	PLEDGED

(Dollars	in	millions)
Derivative	liabilities:

December	31,	2021
Interest	rate	derivative	
contracts
Forward	contracts

December	31,	2020

Interest	rate	derivative	
contracts
Forward	contracts

Gross	amounts
of	recognized
liabilities

Gross
	amounts
offset	in	the
Balance	Sheets

Net	amounts	of
liabilities	presented
in	the	Balance	
Sheets	(a)

Derivative	
assets
available	for
offset

Collateral
pledged

Net	amount

Gross	amounts	not	offset	
	in	the	Balance	Sheets

$	

$	

$	

$	

93	 $	

10	

103	 $	

60	 $	

65	

125	 $	

—	 $	

—	

—	 $	

—	 $	

—	

—	 $	

93	 $	

10	

103	 $	

(32)	 $	

(38)	 $	

(4)	

(1)	

(36)	 $	

(39)	 $	

60	 $	

65	

125	 $	

(7)	 $	

(14)	

(21)	 $	

(31)	 $	

(51)	

(82)	 $	

23	

5	

28	

22	

—	

22	

(a) Included	in	other	liabilities	on	the	Consolidated	Balance	Sheets.	As	of	December	31,	2021	and	2020,	$24	million	and	$22	million,	respectively,	of	

derivative	liabilities	(primarily	Visa-related	derivatives)	have	been	excluded	from	these	tables	because	they	are	generally	not	subject	to	master	netting	or	
similar	agreements.

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NOTE	23—MASTER	NETTING	&	SIMILAR	AGREEMENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 23—Master Netting and Similar Agreements – Repurchase, Reverse 
Repurchase, and Securities Borrowing Transactions

For	repurchase,	reverse	repurchase	and	securities	
borrowing	transactions,	FHN	and	each	counterparty	have	
the	ability	to	offset	all	open	positions	and	related	
collateral	in	the	event	of	default.	Due	to	the	nature	of	
these	transactions,	the	value	of	the	collateral	for	each	
transaction	approximates	the	value	of	the	corresponding	
receivable	or	payable.	For	repurchase	agreements	through	
FHN’s	fixed	income	business	(securities	purchased	under	
agreements	to	resell	and	securities	sold	under	agreements	
to	repurchase),	transactions	are	collateralized	by	
securities	and/or	government	guaranteed	loans	which	are	
delivered	on	the	settlement	date	and	are	maintained	
throughout	the	term	of	the	transaction.	For	FHN’s	
repurchase	agreements	through	banking	activities	
(securities	sold	under	agreements	to	repurchase),	
securities	are	typically	pledged	at	settlement	and	not	
released	until	maturity.	For	asset	positions,	the	collateral	
is	not	included	on	FHN’s	Consolidated	Balance	Sheets.	For	
liability	positions,	securities	collateral	pledged	by	FHN	is	
generally	represented	within	FHN’s	trading	or	available-
for-sale	securities	portfolios.

For	this	disclosure,	FHN	considers	the	impact	of	master	
netting	and	other	similar	agreements	that	allow	FHN	to	
settle	all	contracts	with	a	single	counterparty	on	a	net	
basis	and	to	offset	the	net	asset	or	liability	position	with	
the	related	securities	collateral.	The	application	of	the	
collateral	cannot	reduce	the	net	asset	or	liability	position	
below	zero,	and	therefore	any	excess	collateral	is	not	
reflected	in	the	tables	below.

Securities	purchased	under	agreements	to	resell	is	
included	in	federal	funds	sold	and	securities	purchased	
under	agreements	to	resell	in	the	Consolidated	Balance	
Sheets.	Securities	sold	under	agreements	to	repurchase	is	
included	in	short-term	borrowings.

The	following	table	provides	details	of	securities	
purchased	under	agreements	to	resell	and	collateral	
pledged	by	counterparties	as	of	December	31,	2021	and	
2020:

Table	8.23.1

SECURITIES	PURCHASED	UNDER	AGREEMENTS	TO	RESELL 

Gross	
amounts
of	recognized
assets

Gross	
amounts
offset	in	the
Balance	
Sheets

Net	amounts	of
assets	presented
in	the	Balance	
Sheets

Gross	amounts	not	offset	in	the
Balance	Sheets

Offsetting
securities	sold
under	
agreements
to	repurchase

Securities	
collateral
(not	recognized	on
FHN’s	Balance	
Sheets)

Net	
amount

(Dollars	in	millions)

Securities	purchased	under	
agreements	to	resell:

2021
2020

$	

488	 $	
380	

—	 $	
—	

488	 $	
380	

(10)	 $	
—	

(476)	 $	
(379)	

2	
1	

The	following	table	provides	details	of	securities	sold	under	agreements	to	repurchase	and	collateral	pledged	by	FHN	as	of	
December	31,	2021	and	2020:

Table	8.23.2

SECURITIES	SOLD	UNDER	AGREEMENTS	TO	REPURCHASE 

Gross	amounts	not	offset	in	the
Balance	Sheets

Gross	
amounts
of	recognized
liabilities

Gross	
amounts
offset	in	the
Balance	
Sheets

Net	amounts	of
liabilities	
presented
in	the	Balance	
Sheets

Offsetting	securities
purchased	under
agreements	to	
resell

Securities/
government
guaranteed	
loans
collateral

Net	
amount

$	

1,247	 $	

1,187	

—	 $	

—	

1,247	 $	

1,187	

(10)	 $	

(1,237)	 $	

—	

(1,187)	

—	

—	

(Dollars	in	millions)
Securities	sold	under	
agreements	to	
repurchase:
2021
2020

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NOTE	23—MASTER	NETTING	&	SIMILAR	AGREEMENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Due	to	the	short	duration	of	securities	sold	under	agreements	to	repurchase	and	the	nature	of	collateral	involved,	the	risks	
associated	with	these	transactions	are	considered	minimal.	

The	following	tables	provide	details,	by	collateral	type,	of	the	remaining	contractual	maturity	of	securities	sold	under	
agreements	to	repurchase	as	of	December	31,	2021	and	2020:

Tables	8.23.3a-b

MATURITIES	OF	SECURITIES	SOLD	UNDER	AGREEMENTS	TO	REPURCHASE  
December	31,	2021

(Dollars	in	millions)
Securities	sold	under	agreements	to	repurchase:

U.S.	treasuries

Government	agency	issued	MBS

Other	U.S.	government	agencies

Government	guaranteed	loans	(SBA	and	USDA)

Total	securities	sold	under	agreements	to	repurchase

(Dollars	in	millions)
Securities	sold	under	agreements	to	repurchase:

U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

Government	guaranteed	loans	(SBA	and	USDA)

Overnight	and
Continuous

Up	to	30	Days

Total

$	

$	

33	 $	

—	 $	

1,068	

31	

115	

—	

—	

—	

1,247	 $	

—	 $	

December	31,	2020

Overnight	and
Continuous

Up	to	30	Days

Total

$	

284	 $	

—	 $	

616	

10	

151	

126	

—	

—	

—	

—	

33	

1,068	

31	

115	

1,247	

284	

616	

10	

151	

126	

Total	securities	sold	under	agreements	to	repurchase

$	

1,187	 $	

—	 $	

1,187	

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 24—Fair Value of Assets and Liabilities

FHN	groups	its	assets	and	liabilities	measured	at	fair	value	
in	three	levels,	based	on	the	markets	in	which	the	assets	
and	liabilities	are	traded	and	the	reliability	of	the	
assumptions	used	to	determine	fair	value.	This	hierarchy	
requires	FHN	to	maximize	the	use	of	observable	market	
data,	when	available,	and	to	minimize	the	use	of	
unobservable	inputs	when	determining	fair	value.	Each	
fair	value	measurement	is	placed	into	the	proper	level	
based	on	the	lowest	level	of	significant	input.	These	levels	
are:

• Level	1—Valuation	is	based	upon	quoted	prices	for	

identical	instruments	traded	in	active	markets.

• Level	2—Valuation	is	based	upon	quoted	prices	for	
similar	instruments	in	active	markets,	quoted	prices	
for	identical	or	similar	instruments	in	markets	that	are	
not	active,	and	model-based	valuation	techniques	for	

which	all	significant	assumptions	are	observable	in	
the	market.

• Level	3—Valuation	is	generated	from	model-based	
techniques	that	use	significant	assumptions	not	
observable	in	the	market.	These	unobservable	
assumptions	reflect	management’s	estimates	of	
assumptions	that	market	participants	would	use	in	
pricing	the	asset	or	liability.	Valuation	techniques	
include	use	of	option	pricing	models,	discounted	cash	
flow	models,	and	similar	techniques.

Recurring	Fair	Value	Measurements

The	following	tables	present	the	balances	of	assets	and	
liabilities	measured	at	fair	value	on	a	recurring	basis	as	of	
December	31,	2021	and	2020:	

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Tables	8.24.1a-b

(Dollars	in	millions)
Trading	securities:

U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities

Corporate	and	other	debt

Interest-only	strips	(elected	fair	value)

Total	trading	securities

Loans	held	for	sale	(elected	fair	value)

Securities	available	for	sale:

Government	agency	issued	MBS
Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities

Total	securities	available	for	sale

Other	assets:

Deferred	compensation	mutual	funds

Equity,	mutual	funds,	and	other

Derivatives,	forwards	and	futures

Derivatives,	interest	rate	contracts

Derivatives,	other

Total	other	assets

Total	assets

Trading	liabilities:

U.S.	treasuries

Government	issued	agency	MBS

Corporate	and	other	debt
Total	trading	liabilities

Other	liabilities:

Derivatives,	forwards	and	futures

Derivatives,	interest	rate	contracts

Derivatives,	other

Total	other	liabilities

Total	liabilities

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

BALANCES	OF	ASSETS	&	LIABILITIES
MEASURED	AT	FAIR	VALUE	ON	A	RECURRING	BASIS

Level	1

Level	2

Level	3

Total

December	31,	2021

$	

—	 $	

85	 $	

—	 $	

—	

—	

—	

—	

—	

—	

—	

—	

—	
—	

—	

—	

—	

125	

25	

12	

—	

—	

162	

464	

62	

276	

34	

642	

—	

1,563	

230	

5,055	
2,257	

850	

545	

8,707	

—	

—	

—	

311	

1	

312	

—	

—	

—	

—	

—	

38	

38	

28	

—	
—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

85	

464	

62	

276	

34	

642	

38	

1,601	

258	

5,055	
2,257	

850	

545	

8,707	

125	

25	

12	

311	

1	

474	

162	 $	

10,812	 $	

66	 $	

11,040	

—	 $	

334	 $	

—	 $	

—	

—	
—	

11	

—	

—	

11	

1	

91	
426	

—	

93	

1	

94	

—	

—	
—	

—	

—	

23	

23	

$	

11	 $	

520	 $	

23	 $	

334	

1	

91	
426	

11	

93	

24	

128	

554	

$	

$	

	 194

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(Dollars	in	millions)
Trading	securities:

U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities

Corporate	and	other	debt

Total	trading	securities

Loans	held	for	sale	(elected	fair	value)

Loans	held	for	investment	(elected	fair	value)

Securities	available	for	sale:

U.S.	treasuries

Government	agency	issued	MBS

Government	agency	issued	CMO

Other	U.S.	government	agencies

States	and	municipalities

Corporate	and	other	debt

Interest-only	strips	(elected	fair	value)

Total	securities	available	for	sale

Other	assets:

Deferred	compensation	mutual	funds

Equity,	mutual	funds,	and	other

Derivatives,	forwards	and	futures

Derivatives,	interest	rate	contracts

Derivatives,	other

Total	other	assets

Total	assets

Trading	liabilities:

U.S.	treasuries

Government	agency	issued	MBS

Corporate	and	other	debt

Total	trading	liabilities

Other	liabilities:

Derivatives,	forwards	and	futures

Derivatives,	interest	rate	contracts

Derivatives,	other

Total	other	liabilities

Total	liabilities

Level	1

Level	2

Level	3

Total

December	31,	2020

$	

—	 $	

81	 $	

—	 $	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

118	

25	

63	

—	

—	

206	

633	

212	

62	

7	

181	

1,176	

393	

—	

613	

3,812	

2,406	

684	

460	

40	

—	

8,015	

—	

—	

—	

702	

4	

706	

—	

—	

—	

—	

—	

—	

12	

16	

—	

—	

—	

—	

—	

—	

32	

32	

—	

—	

—	

—	

—	

—	

81	

633	

212	

62	

7	

181	

1,176	

405	

16	

613	

3,812	

2,406	

684	

460	

40	

32	

8,047	

118	

25	

63	

702	

4	

912	

206	 $	

10,290	 $	

60	 $	

10,556	

—	 $	

307	 $	

—	 $	

—	

—	

—	

71	

—	

—	

71	

3	

43	

353	

—	

60	

4	

64	

—	

—	

—	

—	

—	

14	

14	

$	

71	 $	

417	 $	

14	 $	

307	

3	

43	

353	

71	

60	

18	

149	

502	

$	

$	

	 195

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Changes	in	Recurring	Level	3	Fair	Value	Measurements

The	changes	in	Level	3	assets	and	liabilities	measured	at	fair	value	for	the	years	ended	December	31,	2021,	2020	and	2019	on	
a	recurring	basis	are	summarized	as	follows:	

Tables	8.24.2a-b-c

CHANGES	IN	LEVEL	3	ASSETS	&	LIABILITIES	MEASURED	AT	FAIR	VALUE	
Year	Ended	December	31,	2021
Loans	held	
for	
investment

Interest-only	
strips

Loans	held	
for	sale

Net		
derivative
liabilities

(Dollars	in	millions)
Balance	on	January	1,	2021

Total	net	gains	(losses)	included	in	net	income

Purchases

Sales

Settlements

Net	transfers	into	(out	of)	Level	3

Balance	on	December	31,	2021

Net	unrealized	gains	(losses)	included	in	net	income

$	

$	

$	

$	

32	

3	

—	

(68)	

—	

$	

12	

1	

10	

(18)	

(3)	

$	

16	

—	

—	

—	

(2)	

71	 (b)

38	

$	

(2)	 (c) $	

26	 (e)

28	

$	

1	 (a) $	

(14)	 (e)

—	

—	

$	

$	

(14)	

(19)	

—	

—	

10	

—	

(23)	

(19)	 (d)

Year	Ended	December	31,	2020

Trading
securities

Interest-
only	strips-	
AFS

Loans	held	
for	sale

Loans	held	
for	
investment

Net		
derivative
liabilities

$	

(Dollars	in	millions)
Balance	on	January	1,	2020

Acquired
Total	net	gains	(losses)	included	in	net	
income
Purchases

Sales

Settlements

Net	transfers	into	(out	of)	Level	3

Balance	on	December	31,	2020
Net	unrealized	gains	(losses)	included	in	net	
income

$	

$	

(Dollars	in	millions)
Balance	on	January	1,	2019

Total	net	gains	(losses)	included	in	net	income

Purchases

Sales

Settlements

Net	transfers	into	(out	of)	Level	3

Balance	on	December	31,	2019

Net	unrealized	gains	(losses)	included	in	net	income

1	

—	

(1)	

—	

—	

—	

—	

—	

$	

$	

19	

—	

(6)	

6	

(11)	

—	

24	 (b)

$	

32	

$	

14	

—	

1	

—	

—	

(3)	

—	
12	 	

$	

—	 $	

14	

—	

—	

(4)	 	

(3)	 	

9	

(23)	

—	

(1)	

—	

—	

10	

—	

$	

16	 $	

(14)	

—	 (a) $	

(4)	 (c) $	

1	 (a) $	

—	 $	

(1)	 (d)

Year	Ended	December	31,	2019

Trading
securities

Interest-only	
strips-	AFS

Loans	held	
for	sale

Net		
derivative
liabilities

$	

$	

$	

2	

—	

—	

—	

(1)	

—	

1	

$	

$	

—	 (a) $	

$	

10	

(5)	

—	

(47)	

—	

61	 (b)

19	

$	

(2)	 (c) $	

16	

2	

—	

—	

(4)	

—	

14	

$	

(32)	

(4)	

—	

—	

13	

—	

$	

(23)	

2	 (a) $	

(4)	 (d)

(a) Primarily	included	in	mortgage	banking	and	title	income	on	the	Consolidated	Statements	of	Income.
(b) Transfers	into	interest-only	strips	level	3	measured	on	a	recurring	basis	reflect	movements	from	loans	held	for	sale	(Level	2	nonrecurring).
(c) Primarily	included	in	fixed	income	on	the	Consolidated	Statements	of	Income.
(d) Included	in	other	expense.
(e) The	loans	held	for	investment	at	fair	value	option	portfolio	was	transferred	to	the	loans	held	for	sale	portfolio	on	April	1,	2021.

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

There	were	no	net	unrealized	gains	(losses)	for	Level	3	
assets	and	liabilities	included	in	other	comprehensive	
income	as	of	December	31,	2021,	2020	and	2019.

Nonrecurring	Fair	Value	Measurements

From	time	to	time,	FHN	may	be	required	to	measure	
certain	other	financial	assets	at	fair	value	on	a	
nonrecurring	basis	in	accordance	with	GAAP.	These	
adjustments	to	fair	value	usually	result	from	the	

Tables	8.24.3a-b-c

application	of	lower	of	cost	or	market	(LOCOM)	
accounting	or	write-downs	of	individual	assets.	For	assets	
measured	at	fair	value	on	a	nonrecurring	basis	which	were	
still	held	on	the	Consolidated	Balance	Sheets	at	
December	31,	2021,	2020	and	2019,	respectively,	the	
following	tables	provide	the	level	of	valuation	
assumptions	used	to	determine	each	adjustment	and	the	
related	carrying	value. 

LEVEL	OF	VALUATION	ASSUMPTIONS	FOR	ASSETS
MEASURED	AT	FAIR	VALUE	ON	A	NON-RECURRING	BASIS

(Dollars	in	millions)
Loans	held	for	sale—SBAs	and	USDA

Loans	held	for	sale—first	mortgages

Loans	and	leases	(a)

OREO	(b)

Other	assets	(c)

(Dollars	in	millions)
Loans	held	for	sale—SBAs	and	USDA

Loans	held	for	sale—first	mortgages

Loans	and	leases	(a)

OREO	(b)

Other	assets	(c)

Carrying	value	at	December	31,	2021

Level	1

Level	2

Level	3

Total

Year	Ended	December	31,	
2021
Net	gains	(losses)

$	

—	 $	
—	

852	 $	
—	

1	 $	
1	

853	 $	
1	

—	

—	

—	

—	

—	

—	

84	

3	

30	

84	

3	

30	

$	

(2)	
—	

(13)	

(1)	

(2)	

(18)	

Carrying	value	at	December	31,	2020

Level	1

Level	2

Level	3

Total

Year	Ended	December	31,	
2020
Net	gains	(losses)

$	

—	 $	

508	 $	

1	 $	

509	 $	

—	

—	

—	

—	

—	

—	

—	

—	

1	

77	

15	

9	

1	

77	

15	

9	

$	

(3)	

—	

(12)	

(1)	

(2)	

(18)	

Carrying	value	at	December	31,	2019

Year	Ended	December	31,	
2019

(Dollars	in	millions)	

Level	1

Level	2

Level	3

Total

Net	gains	(losses)

Loans	held	for	sale—SBAs	and	USDA

$	

—	 $	

493	 $	

1	 $	

494	 $	

Loans	held	for	sale—first	mortgages

Loans	and	leases	(a)

OREO	(b)

Other	assets	(c)

—	

—	

—	

—	

—	

—	

—	

—	

1	

42	

16	

11	

1	

42	

16	

11	

$	

(2)	

—	

(7)	

(1)	

(2)	

(12)	

(a) Represents	carrying	value	of	loans	for	which	adjustments	are	required	to	be	based	on	the	appraised	value	of	the	collateral	less	estimated	costs	to	sell.	

Write-downs	on	these	loans	are	recognized	as	part	of	provision	for	credit	losses.

(b) Represents	the	fair	value	and	related	losses	of	foreclosed	properties	that	were	measured	subsequent	to	their	initial	classification	as	OREO.	Balance	

excludes	OREO	related	to	government	insured	mortgages.

(c) Represents	tax	credit	investments	accounted	for	under	the	equity	method.

In	2021,	FHN	recognized	$34	million	of	fixed	asset	
impairments	and	$3	million	of	leased	asset	impairments.	
In	2020,	FHN	recognized	$7	million	of	fixed	asset	
impairments	and	$6	million	of	leased	asset	impairments.	
These	impairments	were	primarily	related	to	continuing	
acquisition	integration	efforts	associated	with	reduction	of	

leased	office	space	and	banking	center	optimization.	
These	amounts	were	primarily	recognized	in	the	
Corporate	segment.	

In	2019,	FHN	recognized	$4	million	of	impairments	related	
to	dispositions	of	acquired	properties	and	$1	million	of	

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

leased	asset	impairments	related	to	continuing	acquisition	
integration	efforts	associated	with	reduction	of	leased	
office	space	and	banking	center	optimization.	Related	to	
its	restructuring,	repositioning,	and	efficiency	efforts,	FHN	
recognized	$13	million	of	impairments	for	tangible	long-
lived	assets	and	lease	assets.	Related	to	its	rebranding	
initiative,	FHN recognized	$7	million	of	impairments	for	
long-lived	tangible	assets,	primarily	signage.	These	
amounts	were	primarily	recognized	in	the	Corporate	
segment.

Lease	asset	impairments	recognized	represent	the	
reduction	in	value	of	the	right-of-use	assets	associated	
with	leases	that	are	being	exited	in	advance	of	the	
contractual	lease	expiration.	

Impairments	are	measured	using	a	discounted	cash	flow	
methodology,	which	is	considered	a	Level	3	valuation.	

Impairments	of	long-lived	tangible	assets	reflect	locations	
where	the	associated	land	and	building	are	either	owned	

or	leased.	The	fair	values	of	owned	sites	were	determined	
using	estimated	sales	prices	from	appraisals	and	broker	
opinions	less	estimated	costs	to	sell	with	adjustments	
upon	final	disposition.	The	fair	values	of	owned	assets	in	
leased	sites	(e.g.,	leasehold	improvements)	were	
determined	using	a	discounted	cash	flow	approach,	based	
on	the	revised	estimated	useful	lives	of	the	related	assets.	
Both	measurement	methodologies	are	considered	Level	3	
valuations.	Impairment	adjustments	recognized	upon	
disposition	of	a	location	are	considered	Level	2	valuations.	

Level	3	Measurements

The	following	tables	provide	information	regarding	the	
unobservable	inputs	utilized	in	determining	the	fair	value	
of	Level	3	recurring	and	non-recurring	measurements	as	
of	December	31,	2021	and	2020:  

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ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

UNOBSERVABLE	INPUTS	USED
IN	LEVEL	3	FAIR	VALUE	MEASUREMENTS

Fair	Value	at	
December	31,	
2021

Valuation	Techniques

Unobservable	Input

Range

Weighted	
Average	(d)

Values	Utilized

Table of Contents

Tables	8.24.4a-b

(Dollars	in	millions)

Level	3	Class

Trading	securities	-	SBA	
interest-only	strips

Loans	held	for	sale	-	
residential	real	estate

Loans	held	for	sale	-	
unguaranteed	interest	
in	SBA	loans

Derivative	liabilities,	
other

$	

$	

$	

$	

38	

Discounted	cash	flow

29	

Discounted	cash	flow

1	

Discounted	cash	flow

23	

Discounted	cash	flow

Loans	and	leases	(a)

$	

84	

Appraisals	from	
comparable	properties

Other	collateral	
valuations

OREO	(b)

Other	assets	(c)

$	

$	

Appraisals	from	
comparable	properties

3	

30	

Discounted	cash	flow

Appraisals	from	
comparable	properties

Constant	prepayment	
rate

Bond	equivalent	yield
Prepayment	speeds	-	
First	mortgage

Foreclosure	losses
Loss	severity	trends	-	
First	mortgage

Constant	prepayment	
rate

Bond	equivalent	yield
Visa	covered	litigation	
resolution	amount
Probability	of	
resolution	scenarios

Time	until	resolution
Marketability	
adjustments	for	
specific	properties
Borrowing	base	
certificates	
adjustment
Financial	Statements/
Auction	values	
adjustment
Adjustment	for	value	
changes	since	
appraisal
Adjustments	to	
current	sales	yields	for	
specific	properties
Marketability	
adjustments	for	
specific	properties

11%-12%

11%	-	14%

4%	-	12%

54%	-	66%
1%	-	14%	of	
UPB

8%	-	12%

11%
$5.8	billion	-
	$6.2	billion

15%	-	35%
12	-	36	
months

0%	-	10%	of	
appraisal
20%	-	50%	
of	gross	
value
0%	-	25%	of	
reported	
value

0%	-	10%	of	
appraisal
0%	-	15%	
adjustment	
to	yield

0%	-	25%	of	
appraisal

11%

11%

5%

65%

8%

10%

11%

$6.0	billion

24%

25	months

NM

NM

NM

NM

NM

NM

NM	-	Not	meaningful
(a) Represents	carrying	value	of	loans	for	which	adjustments	are	required	to	be	based	on	the	appraised	value	of	the	collateral	less	estimated	costs	to	sell.	

Write-downs	on	these	loans	are	recognized	as	part	of	provision	for	credit	losses.

(b) Represents	the	fair	value	of	foreclosed	properties	that	were	measured	subsequent	to	their	initial	classification	as	OREO.	Balance	excludes	OREO	related	

to	government	insured	mortgages.

(c) Represents	tax	credit	investments	accounted	for	under	the	equity	method.
(d) Weighted	averages	are	determined	by	the	relative	fair	value	of	the	instruments	or	the	relative	contribution	to	an	instrument's	fair	value.

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Fair	Value	at	
December	31,	
2020

Valuation	Techniques

Unobservable	Input

Range

Weighted	
Average	(d)

Values	Utilized

32	

Discounted	cash	flow

Constant	prepayment	
rate

12%

Bond	equivalent	yield

15%	-	17%

(Dollars	in	millions)

Level	3	Class

Securities	-	SBA	
interest-only	strips

Loans	held	for	sale	-	
residential	real	estate

Loans	held	for	sale	-	
unguaranteed	interest	
in	SBA	loans

Loans	held	for	
investment

Derivative	liabilities,	
other

$	

$	

$	

$	

$	

13	

Discounted	cash	flow

1	

Discounted	cash	flow

16	

Discounted	cash	flow

14	

Discounted	cash	flow

Loans	and	leases	(a)

$	

77	

Appraisals	from	
comparable	properties

Other	collateral	
valuations

OREO	(b)

Other	assets	(c)

$	

$	

Appraisals	from	
comparable	properties

15	

9	

Discounted	cash	flow

Appraisals	from	
comparable	properties

Prepayment	speeds	-	
First	mortgage
Foreclosure	losses
Loss	severity	trends	-	
First	mortgage

Constant	prepayment	
rate

Bond	equivalent	yield
Constant	prepayment	
rate

Constant	default	rate

Loss	severity	trends
Visa	covered	litigation	
resolution	amount
Probability	of	
resolution	scenarios

Time	until	resolution
Marketability	
adjustments	for	
specific	properties
Borrowing	base	
certificates	
adjustment
Financial	Statements/
Auction	values	
adjustment
Adjustment	for	value	
changes	since	
appraisal
Adjustments	to	
current	sales	yields	for	
specific	properties
Marketability	
adjustments	for	
specific	properties

5%	-	15%
59%	-	70%
3%	-	19%	of	
UPB

8%	-	12%

7%-8%

0%	-	26%

0%-14%

0%	-	100%
$5.4	billion	-
	$6.0	billion

10%	-	50%
3	-	27	
months

0%	-	10%	of	
appraisal
20%	-	50%	
of	gross	
value
0%	-	25%	of	
reported	
value

0%	-	10%	of	
appraisal
0%	-	15%	
adjustment	
to	yield

0%	-	25%	of	
appraisal

12%

15%

5%
63%

12%

10%

7%

11%

1%

11%

$5.8	billion

16%

19	months

NM

NM

NM

NM

NM

NM

NM	-	Not	meaningful
(a) Represents	carrying	value	of	loans	for	which	adjustments	are	required	to	be	based	on	the	appraised	value	of	the	collateral	less	estimated	costs	to	sell.	

Write-downs	on	these	loans	are	recognized	as	part	of	provision	for	credit	losses.

(b) Represents	the	fair	value	of	foreclosed	properties	that	were	measured	subsequent	to	their	initial	classification	as	OREO.	Balance	excludes	OREO	related	

to	government	insured	mortgages.

(c) Represents	tax	credit	investments	accounted	for	under	the	equity	method.
(d) Weighted	averages	are	determined	by	the	relative	fair	value	of	the	instruments	or	the	relative	contribution	to	an	instrument's	fair	value.

Trading	Securities	-	SBA	interest-only	strips

Increases	(decreases)	in	estimated	prepayment	rates	and	
bond	equivalent	yields	negatively	(positively)	affect	the	

value	of	SBA	interest-only	strips.	Management	additionally	
considers	whether	the	loans	underlying	related	SBA	

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

interest-only	strips	are	delinquent,	in	default	or	prepaying,	
and	adjusts	the	fair	value	down	20	-	100%	depending	on	
the	length	of	time	in	default.	SBA	interest-only	strips	were	
transferred	from	AFS	to	trading	securities	on	October	1,	
2021.

Loans	held	for	sale

Foreclosure	losses	and	prepayment	rates	are	significant	
unobservable	inputs	used	in	the	fair	value	measurement	
of	FHN’s	residential	real	estate	loans	held	for	sale.	Loss	
severity	trends	are	also	assessed	to	evaluate	the	
reasonableness	of	fair	value	estimates	resulting	from	
discounted	cash	flows	methodologies	as	well	as	to	
estimate	fair	value	for	newly	repurchased	loans	and	loans	
that	are	near	foreclosure.	Significant	increases	(decreases)	
in	any	of	these	inputs	in	isolation	would	result	in	
significantly	lower	(higher)	fair	value	measurements.	All	
observable	and	unobservable	inputs	are	re-assessed	
quarterly.

Increases	(decreases)	in	estimated	prepayment	rates	and	
bond	equivalent	yields	negatively	(positively)	affect	the	
value	of	unguaranteed	interests	in	SBA	loans.	
Unguaranteed	interest	in	SBA	loans	held	for	sale	are	
carried	at	less	than	the	outstanding	balance	due	to	credit	
risk	estimates.	Credit	risk	adjustments	may	be	reduced	if	
prepayment	is	likely	or	as	consistent	payment	history	is	
realized.	Management	also	considers	other	factors	such	as	
delinquency	or	default	and	adjusts	the	fair	value	
accordingly.

Loans	held	for	investment

Constant	prepayment	rate,	constant	default	rate	and	loss	
severity	trends	are	significant	unobservable	inputs	used	in	
the	fair	value	measurement	of	loans	held	for	investment.	
Increases	(decreases)	in	each	of	these	inputs	in	isolation	
result	in	negative	(positive)	effects	on	the	valuation	of	the	
associated	loans.

Derivative	liabilities

In	conjunction	with	pre-2020	sales	of	Visa	Class	B	shares,	
FHN	and	the	purchasers	entered	into	derivative	
transactions	whereby	FHN	will	make,	or	receive,	cash	
payments	whenever	the	conversion	ratio	of	the	Visa	Class	
B	shares	into	Visa	Class	A	shares	is	adjusted.	FHN	uses	a	
discounted	cash	flow	methodology	in	order	to	estimate	
the	fair	value	of	FHN’s	derivative	liabilities	associated	with	
its	prior	sales	of	Visa	Class	B	shares.	The	methodology	
includes	estimation	of	both	the	resolution	amount	for	
Visa’s	Covered	Litigation	matters	as	well	as	the	length	of	
time	until	the	resolution	occurs.	Significant	increases	
(decreases)	in	either	of	these	inputs	in	isolation	would	
result	in	significantly	higher	(lower)	fair	value	
measurements	for	the	derivative	liabilities.	Additionally,	
FHN	performs	a	probability	weighted	multiple	resolution	
scenario	to	calculate	the	estimated	fair	value	of	these	
derivative	liabilities.	Assignment	of	higher	(lower)	
probabilities	to	the	larger	potential	resolution	scenarios	

would	result	in	an	increase	(decrease)	in	the	estimated	fair	
value	of	the	derivative	liabilities.	Since	this	estimation	
process	requires	application	of	judgment	in	developing	
significant	unobservable	inputs	used	to	determine	the	
possible	outcomes	and	the	probability	weighting	assigned	
to	each	scenario,	these	derivatives	have	been	classified	
within	Level	3	in	fair	value	measurements	disclosures.	

Loans	and	leases	and	Other	Real	Estate	Owned

Collateral-dependent	loans	and	OREO	are	primarily	valued	
using	appraisals	based	on	sales	of	comparable	properties	
in	the	same	or	similar	markets.	Other	collateral	
(receivables,	inventory,	equipment,	etc.)	is	valued	through	
borrowing	base	certificates,	financial	statements	and/or	
auction	valuations.	These	valuations	are	discounted	based	
on	the	quality	of	reporting,	knowledge	of	the	
marketability/collectability	of	the	collateral	and	historical	
disposition	rates.

Other	assets	–	tax	credit	investments

The	estimated	fair	value	of	tax	credit	investments	
accounted	for	under	the	equity	method	is	generally	
determined	in	relation	to	the	yield	(i.e.,	future	tax	credits	
to	be	received)	an	acquirer	of	these	investments	would	
expect	in	relation	to	the	yields	experienced	on	current	
new	issue	and/or	secondary	market	transactions.	Thus,	as	
tax	credits	are	recognized,	the	future	yield	to	a	market	
participant	is	reduced,	resulting	in	consistent	impairment	
of	the	individual	investments.	Individual	investments	are	
reviewed	for	impairment	quarterly,	which	may	include	the	
consideration	of	additional	marketability	discounts	related	
to	specific	investments	which	typically	includes	
consideration	of	the	underlying	property’s	appraised	
value.

Fair	Value	Option

FHN	has	elected	the	fair	value	option	on	a	prospective	
basis	for	substantially	all	types	of	mortgage	loans	
originated	for	sale	purposes	except	for	mortgage	
origination	operations	which	utilize	the	platform	acquired	
from	CBF.	FHN	determined	that	the	election	reduces	
certain	timing	differences	and	better	matches	changes	in	
the	value	of	such	loans	with	changes	in	the	value	of	
derivatives	and	forward	delivery	commitments	used	as	
economic	hedges	for	these	assets	at	the	time	of	election.

Repurchased	loans	relating	to	mortgage	banking	
operations	conducted	prior	to	the	IBKC	merger	are	
recognized	within	loans	held	for	sale	at	fair	value	at	the	
time	of	repurchase,	which	includes	consideration	of	the	
credit	status	of	the	loans	and	the	estimated	liquidation	
value.	FHN	has	elected	to	continue	recognition	of	these	
loans	at	fair	value	in	periods	subsequent	to	reacquisition.	
Due	to	the	credit-distressed	nature	of	the	vast	majority	of	
repurchased	loans	and	the	related	loss	severities	
experienced	upon	repurchase,	FHN	believes	that	the	fair	
value	election	provides	a	more	timely	recognition	of	
changes	in	value	for	these	loans	that	occur	subsequent	to	

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

repurchase.	Absent	the	fair	value	election,	these	loans	
would	be	subject	to	valuation	at	the	LOCOM	value,	which	
would	prevent	subsequent	values	from	exceeding	the	
initial	fair	value,	determined	at	the	time	of	repurchase,	
but	would	require	recognition	of	subsequent	declines	in	
value.	Thus,	the	fair	value	election	provides	for	a	more	
timely	recognition	of	any	potential	future	recoveries	in	
asset	values	while	not	affecting	the	requirement	to	
recognize	subsequent	declines	in	value.

FHN	also	had	a	portion	of	mortgage	loans	held	for	
investment	for	which	the	fair	value	option	was	elected	

Tables	8.24.5a-b

upon	origination	and	which	were	accounted	for	at	fair	
value.	This	portion	of	mortgage	loans	held	for	investment	
at	fair	value	option	was	transferred	to	the	loans	held	for	
sale	portfolio	on	April	1,	2021.

The	following	tables	reflect	the	differences	between	the	
fair	value	carrying	amount	of	residential	real	estate	loans	
held	for	sale	and	held	for	investment	measured	at	fair	
value	in	accordance	with	management’s	election	and	the	
aggregate	unpaid	principal	amount	FHN	is	contractually	
entitled	to	receive	at	maturity.

DIFFERENCES	BETWEEN	FAIR	VALUE	CARRYING	AMOUNTS
AND	CONTRACTUAL	AMOUNTS	OF	RESIDENTIAL	REAL	ESTATE	LOANS

(Dollars	in	millions)
Residential	real	estate	loans	held	for	sale	reported	at	fair	value:

Total	loans
Nonaccrual	loans

(Dollars	in	millions)
Residential	real	estate	loans	held	for	sale	reported	at	fair	value:

Total	loans
Nonaccrual	loans

Loans	held	for	investment	reported	at	fair	value:	

Total	loans
Nonaccrual	loans

Assets	and	liabilities	accounted	for	under	the	fair	value	
election	are	initially	measured	at	fair	value	with	
subsequent	changes	in	fair	value	recognized	in	earnings.	
Such	changes	in	the	fair	value	of	assets	and	liabilities	for	

Table	8.24.6

December	31,	2021

Fair	value
carrying
amount

Aggregate
unpaid
principal

Fair	value	carrying	amount
less	aggregate	unpaid
principal

258	 $	
4	

264	 $	
7	

(6)	
(3)	

December	31,	2020

Fair	value
carrying
amount

Aggregate
unpaid
principal

Fair	value	carrying	amount
less	aggregate	unpaid
principal

405	 $	
2	

442	 $	
5	

16	
1	

17	
1	

(37)	
(3)	

(1)	
—	

$	

$	

which	FHN	elected	the	fair	value	option	are	included	in	
current	period	earnings	with	classification	in	the	income	
statement	line	item	reflected	in	the	following	table:	

CHANGES	IN	FAIR	VALUE	RECOGNIZED	IN	NET	INCOME

(Dollars	in	millions)
Changes	in	fair	value	included	in	net	income:

Mortgage	banking	and	title	noninterest	income

Loans	held	for	sale

For	the	years	ended	December	31,	2021,	2020	and	2019,	
the	amount	for	residential	real	estate	loans	held	for	sale	
included	an	insignificant	amount	of	gains	in	pretax	
earnings	that	are	attributable	to	changes	in	instrument-
specific	credit	risk.	The	portion	of	the	fair	value	
adjustments	related	to	credit	risk	was	determined	based	
on	estimated	default	rates	and	estimated	loss	severities.	
Interest	income	on	residential	real	estate	loans	held	for	
sale	measured	at	fair	value	is	calculated	based	on	the	note	
rate	of	the	loan	and	is	recorded	in	the	interest	income	

Year	Ended	December	31,
2020

2019

2021

$	

(10)	 $	

4	 $	

2	

section	of	the	Consolidated	Statements	of	Income	as	
interest	on	loans	held	for	sale.

FHN	has	elected	to	account	for	retained	interest-only	
strips	from	guaranteed	SBA	loans	recorded	in	trading	
securities	at	fair	value	through	earnings.	Since	these	
securities	are	subject	to	the	risk	that	prepayments	may	
result	in	FHN	not	recovering	all	or	a	portion	of	its	recorded	
investment,	the	fair	value	election	results	in	a	more	timely	
recognition	of	the	effects	of	estimated	prepayments	
through	earnings	rather	than	being	recognized	through	

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

other	comprehensive	income	with	periodic	review	for	
other-than-temporary	impairment.	Gains	or	losses	are	
recognized	through	fixed	income	revenues	and	are	
presented	in	the	recurring	measurements	table.

Determination	of	Fair	Value

Fair	values	are	based	on	the	price	that	would	be	received	
to	sell	an	asset	or	paid	to	transfer	a	liability	in	an	orderly	
transaction	between	market	participants	at	the	
measurement	date.	The	following	describes	the	
assumptions	and	methodologies	used	to	estimate	the	fair	
value	of	financial	instruments	recorded	at	fair	value	in	the	
Consolidated	Balance	Sheets	and	for	estimating	the	fair	
value	of	financial	instruments	for	which	fair	value	is	
disclosed.

Short-term	financial	assets

Federal	funds	sold,	securities	purchased	under	
agreements	to	resell,	and	interest-bearing	deposits	with	
other	financial	institutions	and	the	Federal	Reserve	are	
carried	at	historical	cost.	The	carrying	amount	is	a	
reasonable	estimate	of	fair	value	because	of	the	relatively	
short	time	between	the	origination	of	the	instrument	and	
its	expected	realization.

Trading	securities	and	trading	liabilities

Trading	securities	and	trading	liabilities	are	recognized	at	
fair	value	through	current	earnings.	Trading	inventory	held	
for	broker-dealer	operations	is	included	in	trading	
securities	and	trading	liabilities.	Broker-dealer	long	
positions	are	valued	at	bid	price	in	the	bid-ask	spread.	
Short	positions	are	valued	at	the	ask	price.	Inventory	
positions	are	valued	using	observable	inputs	including	
current	market	transactions,	benchmark	yields,	credit	
spreads	and	consensus	prepayment	speeds.	Trading	loans	
are	valued	using	observable	inputs	including	current	
market	transactions,	swap	rates,	mortgage	rates,	and	
consensus	prepayment	speeds.

Trading	securities	-	SBA	interest-only	strips

Interest-only	strips	are	valued	at	elected	fair	value	based	
on	an	income	approach	using	an	internal	valuation	model.	
The	internal	valuation	model	includes	assumptions	
regarding	projections	of	future	cash	flows,	prepayment	
rates,	default	rates	and	interest-only	strip	terms.	These	
securities	bear	the	risk	of	loan	prepayment	or	default	that	
may	result	in	FHN	not	recovering	all	or	a	portion	of	its	
recorded	investment.	When	appropriate,	valuations	are	
adjusted	for	various	factors	including	default	or	
prepayment	status	of	the	underlying	SBA	loans.	Because	
of	the	inherent	uncertainty	of	valuation,	those	estimated	
values	may	be	higher	or	lower	than	the	values	that	would	
have	been	used	had	a	ready	market	for	the	securities	
existed,	and	may	change	in	the	near	term.	SBA	interest-

only	strips	were	transferred	from	AFS	to	trading	on	
October	1,	2021.

Securities	available	for	sale	and	held	to	maturity

Valuations	of	debt	securities	are	performed	using	
observable	inputs	obtained	from	market	transactions	in	
similar	securities.	Typical	inputs	include	benchmark	yields,	
consensus	prepayment	speeds	and	credit	spreads.	Trades	
from	similar	securities	and	broker	quotes	are	used	to	
support	these	valuations.

Loans	held	for	sale

FHN	determines	the	fair	value	of	loans	held	for	sale	using	
either	current	transaction	prices	or	discounted	cash	flow	
models.	Fair	values	are	determined	using	current	
transaction	prices	and/or	values	on	similar	assets	when	
available,	including	committed	bids	for	specific	loans	or	
loan	portfolios.	Uncommitted	bids	may	be	adjusted	based	
on	other	available	market	information.	

Fair	value	of	residential	real	estate	loans	held	for	sale	
determined	using	a	discounted	cash	flow	model	
incorporates	both	observable	and	unobservable	inputs.	
Inputs	in	the	discounted	cash	flow	model	include	current	
mortgage	rates	for	similar	products,	estimated	
prepayment	rates,	foreclosure	losses,	and	various	loan	
performance	measures	(delinquency,	LTV,	credit	score).	
Adjustments	for	delinquency	and	other	differences	in	loan	
characteristics	are	typically	reflected	in	the	model’s	
discount	rates.	Loss	severity	trends	and	the	value	of	
underlying	collateral	are	also	considered	in	assessing	the	
appropriate	fair	value	for	severely	delinquent	loans	and	
loans	in	foreclosure.	The	valuation	of	HELOCs	also	
incorporates	estimated	cancellation	rates	for	loans	
expected	to	become	delinquent.

Non-mortgage	consumer	loans	held	for	sale	are	valued	
using	committed	bids	for	specific	loans	or	loan	portfolios	
or	current	market	pricing	for	similar	assets	with	
adjustments	for	differences	in	credit	standing	
(delinquency,	historical	default	rates	for	similar	loans),	
yield,	collateral	values	and	prepayment	rates.	If	pricing	for	
similar	assets	is	not	available,	a	discounted	cash	flow	
methodology	is	utilized,	which	incorporates	all	of	these	
factors	into	an	estimate	of	investor	required	yield	for	the	
discount	rate.

FHN	utilizes	quoted	market	prices	of	similar	instruments	
or	broker	and	dealer	quotations	to	value	the	SBA	and	
USDA	guaranteed	loans.	FHN	values	SBA-unguaranteed	
interests	in	loans	held	for	sale	based	on	individual	loan	
characteristics,	such	as	industry	type	and	pay	history	
which	generally	follows	an	income	approach.	
Furthermore,	these	valuations	are	adjusted	for	changes	in	
prepayment	estimates	and	are	reduced	due	to	restrictions	
on	trading.	The	fair	value	of	other	non-residential	real	
estate	loans	held	for	sale	is	approximated	by	their	carrying	
values	based	on	current	transaction	values.

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Mortgage	loans	held	for	investment	at	fair	value	option

The	fair	value	of	mortgage	loans	held	for	investment	at	
fair	value	option	is	determined	by	a	third	party	using	a	
discounted	cash	flow	model	using	various	assumptions	
about	future	loan	performance	(constant	prepayment	
rate,	constant	default	rate	and	loss	severity	trends)	and	
market	discount	rates.

Loans	held	for	investment

The	fair	values	of	mortgage	loans	are	estimated	using	an	
exit	price	methodology	that	is	based	on	present	values	
using	the	interest	rate	that	would	be	charged	for	a	similar	
loan	to	a	borrower	with	similar	risk,	weighted	for	varying	
maturity	dates	and	adjusted	for	a	liquidity	discount	based	
on	the	estimated	time	period	to	complete	a	sale	
transaction	with	a	market	participant.

Other	loans	and	leases	are	valued	based	on	present	values	
using	the	interest	rate	that	would	be	charged	for	a	similar	
instrument	to	a	borrower	with	similar	risk,	applicable	to	
each	category	of	instruments,	and	adjusted	for	a	liquidity	
discount	based	on	the	estimated	time	period	to	complete	
a	sale	transaction	with	a	market	participant.

For	loans	measured	using	the	estimated	fair	value	of	
collateral	less	costs	to	sell,	fair	value	is	estimated	using	
appraisals	of	the	collateral.	Collateral	values	are	
monitored	and	additional	write-downs	are	recognized	if	it	
is	determined	that	the	estimated	collateral	values	have	
declined	further.	Estimated	costs	to	sell	are	based	on	
current	amounts	of	disposal	costs	for	similar	assets.	
Carrying	value	is	considered	to	reflect	fair	value	for	these	
loans.

Derivative	assets	and	liabilities

The	fair	value	for	forwards	and	futures	contracts	is	based	
on	current	transactions	involving	identical	securities.	
Futures	contracts	are	exchange-traded	and	thus	have	no	
credit	risk	factor	assigned	as	the	risk	of	non-performance	
is	limited	to	the	clearinghouse	used.

Valuations	of	other	derivatives	(primarily	interest	rate	
contracts)	are	based	on	inputs	observed	in	active	markets	
for	similar	instruments.	Typically	inputs	include	
benchmark	yields,	option	volatility	and	option	skew.		
Starting	in	October	2020,	centrally	cleared	derivatives	are	
discounted	using	SOFR	as	required	by	clearinghouses.	In	
measuring	the	fair	value	of	these	derivative	assets	and	
liabilities,	FHN	has	elected	to	consider	credit	risk	based	on	
the	net	exposure	to	individual	counterparties.	Credit	risk	is	
mitigated	for	these	instruments	through	the	use	of	mutual	
margining	and	master	netting	agreements	as	well	as	
collateral	posting	requirements.	For	derivative	contracts	
with	daily	cash	margin	requirements	that	are	considered	
settlements,	the	daily	margin	amount	is	netted	within	
derivative	assets	or	liabilities.	Any	remaining	credit	risk	
related	to	interest	rate	derivatives	is	considered	in	
determining	fair	value	through	evaluation	of	additional	

factors	such	as	client	loan	grades	and	debt	ratings.	Foreign	
currency	related	derivatives	also	utilize	observable	
exchange	rates	in	the	determination	of	fair	value.	The	
determination	of	fair	value	for	FHN’s	derivative	liabilities	
associated	with	its	prior	sales	of	Visa	Class	B	shares	are	
classified	within	Level	3	in	the	fair	value	measurements	
disclosure	as	previously	discussed	in	the	unobservable	
inputs	discussion.

The	fair	value	of	risk	participations	is	determined	in	
reference	to	the	fair	value	of	the	related	derivative	
contract	between	the	borrower	and	the	lead	bank	in	the	
participation	structure,	which	is	determined	consistent	
with	the	valuation	process	discussed	above.	This	value	is	
adjusted	for	the	pro	rata	portion	of	the	reference	
derivative’s	notional	value	and	an	assessment	of	credit	
risk	for	the	referenced	borrower.

OREO

OREO	primarily	consists	of	properties	that	have	been	
acquired	in	satisfaction	of	debt.	These	properties	are	
carried	at	the	lower	of	the	outstanding	loan	amount	or	
estimated	fair	value	less	estimated	costs	to	sell	the	real	
estate.	Estimated	fair	value	is	determined	using	appraised	
values	with	subsequent	adjustments	for	deterioration	in	
values	that	are	not	reflected	in	the	most	recent	appraisal.

Other	assets

For	disclosure	purposes,	other	assets	consist	of	tax	credit	
investments,	FRB	and	FHLB	Stock,	deferred	compensation	
mutual	funds	and	equity	investments	(including	other	
mutual	funds)	with	readily	determinable	fair	values.	Tax	
credit	investments	accounted	for	under	the	equity	
method	are	written	down	to	estimated	fair	value	quarterly	
based	on	the	estimated	value	of	the	associated	tax	credits	
which	incorporates	estimates	of	required	yield	for	
hypothetical	investors.	The	fair	value	of	all	other	tax	credit	
investments	is	estimated	using	recent	transaction	
information	with	adjustments	for	differences	in	individual	
investments.	Deferred	compensation	mutual	funds	are	
recognized	at	fair	value,	which	is	based	on	quoted	prices	
in	active	markets.

Investments	in	the	stock	of	the	Federal	Reserve	Bank	and	
Federal	Home	Loan	Banks	are	recognized	at	historical	cost	
in	the	Consolidated	Balance	Sheets	which	is	considered	to	
approximate	fair	value.	Investments	in	mutual	funds	are	
measured	at	the	funds’	reported	closing	net	asset	values.	
Investments	in	equity	securities	are	valued	using	quoted	
market	prices	when	available.	

Defined	maturity	deposits

The	fair	value	of	these	deposits	is	estimated	by	
discounting	future	cash	flows	to	their	present	value.	
Future	cash	flows	are	discounted	by	using	the	current	
market	rates	of	similar	instruments	applicable	to	the	
remaining	maturity.	For	disclosure	purposes,	defined	
maturity	deposits	include	all	time	deposits.

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NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Short-term	financial	liabilities

The	fair	value	of	federal	funds	purchased,	securities	sold	
under	agreements	to	repurchase	and	other	short-term	
borrowings	are	approximated	by	the	book	value.	The	
carrying	amount	is	a	reasonable	estimate	of	fair	value	
because	of	the	relatively	short	time	between	the	
origination	of	the	instrument	and	its	expected	realization.

Loan	commitments

Fair	values	of	these	commitments	are	based	on	fees	
charged	to	enter	into	similar	agreements	taking	into	
account	the	remaining	terms	of	the	agreements	and	the	
counterparties’	credit	standing.

Other	commitments

Fair	values	of	these	commitments	are	based	on	fees	
charged	to	enter	into	similar	agreements.

The	following	fair	value	estimates	are	determined	as	of	a	
specific	point	in	time	utilizing	various	assumptions	and	
estimates.	The	use	of	assumptions	and	various	valuation	
techniques,	as	well	as	the	absence	of	secondary	markets	
for	certain	financial	instruments,	reduces	the	
comparability	of	fair	value	disclosures	between	financial	
institutions.	Due	to	market	illiquidity,	the	fair	values	for	
loans	and	leases,	loans	held	for	sale,	and	term	borrowings	
as	of	December	31,	2021	and	December	31,	2020,	involve	
the	use	of	significant	internally-developed	pricing	
assumptions	for	certain	components	of	these	line	items.	
The	assumptions	and	valuations	utilized	for	this	disclosure	

are	considered	to	reflect	inputs	that	market	participants	
would	use	in	transactions	involving	these	instruments	as	
of	the	measurement	date.	The	valuations	of	legacy	assets,	
particularly	consumer	loans	and	TRUPS	loans	within	the	
Corporate	segment,	are	influenced	by	changes	in	
economic	conditions	since	origination	and	risk	perceptions	
of	the	financial	sector.	These	considerations	affect	the	
estimate	of	a	potential	acquirer’s	cost	of	capital	and	cash	
flow	volatility	assumptions	from	these	assets	and	the	
resulting	fair	value	measurements	may	depart	significantly	
from	FHN’s	internal	estimates	of	the	intrinsic	value	of	
these	assets.

Assets	and	liabilities	that	are	not	financial	instruments	
have	not	been	included	in	the	following	table	such	as	the	
value	of	long-term	relationships	with	deposit	and	trust	
clients,	premises	and	equipment,	goodwill	and	other	
intangibles,	deferred	taxes,	and	certain	other	assets	and	
other	liabilities.	Additionally,	these	measurements	are	
solely	for	financial	instruments	as	of	the	measurement	
date	and	do	not	consider	the	earnings	potential	of	our	
various	business	lines.	Accordingly,	the	total	of	the	fair	
value	amounts	does	not	represent,	and	should	not	be	
construed	to	represent,	the	underlying	value	of	FHN.

The	following	tables	summarize	the	book	value	and	
estimated	fair	value	of	financial	instruments	recorded	in	
the	Consolidated	Balance	Sheets	as	of	December	31,	2021	
and	December	31,	2020:

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Table of Contents

Tables	8.24.7a-b

(Dollars	in	millions)	

Assets:

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

BOOK	VALUE	AND	ESTIMATED	FAIR	VALUE	OF	FINANCIAL	INSTRUMENTS

Book
Value

December	31,	2021

Fair	Value

Level	1

Level	2

Level	3

Total

Loans	and	leases,	net	of	allowance	for	loan	and	lease	losses

Commercial:

Commercial,	financial	and	industrial

$	

30,734	

$	

Commercial	real	estate

Consumer:

Consumer	real	estate	

Credit	card	and	other

Total	loans	and	leases,	net	of	allowance	for	loan	and	lease	
losses

Short-term	financial	assets:

Interest-bearing	deposits	with	banks

Federal	funds	sold

Securities	purchased	under	agreements	to	resell

Total	short-term	financial	assets

Trading	securities	(a)

Loans	held	for	sale:

Mortgage	loans	(elected	fair	value)	(a)

USDA	&	SBA	loans	-	LOCOM

Other	loans	-	LOCOM

Mortgage	loans	-	LOCOM

Total	loans	held	for	sale

Securities	available	for	sale	(a)	

Securities	held	to	maturity

Derivative	assets	(a)

Other	assets:

Tax	credit	investments

Deferred	compensation	mutual	funds

Equity,	mutual	funds,	and	other	(b)

Total	other	assets

Total	assets

Liabilities:

Defined	maturity	deposits

Trading	liabilities	(a)

Short-term	financial	liabilities:

Federal	funds	purchased

Securities	sold	under	agreements	to	repurchase

Other	short-term	borrowings

Total	short-term	financial	liabilities

Term	borrowings:

Real	estate	investment	trust-preferred

Term	borrowings—new	market	tax	credit	investment

Secured	borrowings

Junior	subordinated	debentures

Other	long	term	borrowings

Total	term	borrowings

Derivative	liabilities	(a)

Total	liabilities

11,955	

10,609	

891	

54,189	

14,907	

153	

488	

15,548	

1,601	

258	

853	

24	

37	

1,172	

8,707	

712	

324	

456	

125	

257	

838	

3,500	

$	

426	

775	

1,247	

102	

2,124	

46	

59	

6	

148	

1,331	

1,590	

128	

$	

—	

—	

—	

—	

—	

14,907	

—	

—	

14,907	

—	

—	

—	

—	

—	

—	

—	

—	

12	

—	

125	

25	

150	

—	

—	

—	

—	

—	

—	

153	

488	

641	

1,563	

230	

855	

24	

—	

1,109	

8,707	

705	

312	

—	

—	

—	

—	

$	

31,020	

$	

11,986	

11,111	

906	

55,023	

—	

—	

—	

—	

38	

28	

1	

—	

37	

66	

—	

—	

—	

450	

—	

232	

682	

31,020	

11,986	

11,111	

906	

55,023	

14,907	

153	

488	

15,548	

1,601	

258	

856	

24	

37	

1,175	

8,707	

705	

324	

450	

125	

257	

832	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

11	

11	

$	

3,524	

$	

426	

775	

1,247	

102	

2,124	

—	

—	

—	

—	

1,452	

1,452	

94	

$	

—	

—	

—	

—	

—	

—	

47	

58	

6	

150	

—	

261	

23	

$	

7,620	

$	

284	

$	

3,524	

426	

775	

1,247	

102	

2,124	

47	

58	

6	

150	

1,452	

1,713	

128	

7,915	

83,091	

$	

15,069	

$	

13,037	

$	

55,809	

$	

83,915	

$	

$	

$	

7,768	

$	

(a) Classes	are	detailed	in	the	recurring	and	nonrecurring	measurement	tables.
(b) Level	1	primarily	consists	of	mutual	funds	with	readily	determinable	fair	values.	Level	3	includes	restricted	investments	in	FHLB-Cincinnati	stock	of	$29	

million	and	FRB	stock	of	$203	million.

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Table of Contents

NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

(Dollars	in	millions)

Assets:

Book
Value

December	31,	2020

Fair	Value

Level	1

Level	2

Level	3

Total

Loans	and	leases,	net	of	allowance	for	loan	and	lease	losses

Commercial:

Commercial,	financial	and	industrial

$	

32,651	

$	

Commercial	real	estate

Consumer:

Consumer	real	estate

Credit	card	and	other

Total	loans	and	leases,	net	of	allowance	for	loan	and	lease	
losses

Short-term	financial	assets:

Interest-bearing	deposits	with	banks

Federal	funds	sold

Securities	purchased	under	agreements	to	resell

Total	short-term	financial	assets

Trading	securities	(a)

Loans	held	for	sale:

Mortgage	loans	(elected	fair	value)	(a)

USDA	&	SBA	loans	-	LOCOM

Other	loans	-	LOCOM

Mortgage	loans	-	LOCOM

Total	loans	held	for	sale

Securities	available	for	sale	(a)	

Securities	held	to	maturity

Derivative	assets	(a)

Other	assets:

Tax	credit	investments

Deferred	compensation	mutual	funds

Equity,	mutual	funds,	and	other	(b)

Total	other	assets

Total	assets

Liabilities:

Defined	maturity	deposits

Trading	liabilities	(a)

Short-term	financial	liabilities:

Federal	funds	purchased

Securities	sold	under	agreements	to	repurchase

Other	short-term	borrowings

Total	short-term	financial	liabilities

Term	borrowings:

Real	estate	investment	trust-preferred

Term	borrowings—new	market	tax	credit	investment

Secured	borrowings

Junior	subordinated	debentures

Other	long	term	borrowings

Total	term	borrowings

Derivative	liabilities	(a)

Total	liabilities

12,033	

11,483	

1,102	

57,269	

8,351	

65	

380	

8,796	

1,176	

405	

509	

31	

77	

1,022	

8,047	

10	

769	

400	

118	

288	

806	

5,070	

$	

353	

845	

1,187	

166	

2,198	

46	

45	

15	

238	

1,326	

1,670	

149	

$	

—	

—	

—	

—	

—	

8,351	

—	

—	

8,351	

—	

—	

—	

—	

—	

—	

—	

—	

63	

—	

118	

25	

143	

—	

—	

—	

—	

—	

—	

65	

380	

445	

1,176	

393	

511	

31	

—	

935	

8,015	

—	

706	

—	

—	

—	

—	

$	

32,582	

$	

12,079	

11,903	

1,131	

57,695	

—	

—	

—	

—	

—	

12	

1	

—	

77	

90	

32	

10	

—	

371	

—	

263	

634	

32,582	

12,079	

11,903	

1,131	

57,695	

8,351	

65	

380	

8,796	

1,176	

405	

512	

31	

77	

1,025	

8,047	

10	

769	

371	

118	

288	

777	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

—	

71	

71	

$	

5,083	

$	

353	

845	

1,187	

166	

2,198	

—	

—	

—	

—	

1,455	

1,455	

64	

$	

—	

—	

—	

—	

—	

—	

47	

45	

15	

223	

—	

330	

14	

$	

9,153	

$	

344	

$	

5,083	

353	

845	

1,187	

166	

2,198	

47	

45	

15	

223	

1,455	

1,785	

149	

9,568	

77,895	

$	

8,557	

$	

11,277	

$	

58,461	

$	

78,295	

$	

$	

$	

9,440	

$	

(a) Classes	are	detailed	in	the	recurring	and	nonrecurring	measurement	tables.
(b) Level	1	primarily	consists	of	mutual	funds	with	readily	determinable	fair	values.	Level	3	includes	restricted	investments	in	FHLB-Cincinnati	stock	of	$61	

million	and	FRB	stock	of	$202	million.

	 207

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
Table of Contents

NOTE	24—FAIR	VALUE	OF	ASSETS	AND	LIABILITIES

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

The	following	table	presents	the	contractual	amount	and	fair	value	of	unfunded	loan	commitments	and	standby	and	other	
commitments	as	of	December	31,	2021	and	December	31,	2020:

Table	8.24.8

(Dollars	in	millions)
Unfunded	Commitments:
Loan	commitments

Standby	and	other	commitments

UNFUNDED	COMMITMENTS

Contractual	Amount

December	31,	
2021

December	31,	
2020

December	31,	
2021

Fair	Value

December	31,	
2020

$	

24,229	 $	
810	

20,796	 $	
751	

1	 $	
6	

2	

6	

	 208

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
    
Table of Contents

NOTE	25—RESTRUCTURING,	REPOSITIONING,	&	EFFICIENCY

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 25—Restructuring, Repositioning, and Efficiency

Beginning	in	2019,	FHN	initiated	a	company-wide	review	
of	business	practices	with	the	goal	of	optimizing	its	
expense	base	to	improve	profitability	and	create	capacity	
to	reinvest	savings	into	technology	and	revenue	
production	activities.	Restructuring,	repositioning,	and	
efficiency	charges	related	to	these	corporate-driven	
actions	were	not	significant	in	2021	and	2020	and	were	
$40	million	in	2019.	These	expenses	are	included	in	the	
Corporate	segment.	Significant	expenses	resulted	from	
the	following	actions:	

• Severance	and	other	employee	costs	primarily	related	
to	efficiency	initiatives	within	corporate	and	bank	
services	functions	which	are	classified	as	personnel	
expense	within	noninterest	expense.	

• Expense	largely	related	to	the	identification	of	

efficiency	opportunities	within	the	organization	which	
is	reflected	in	legal	and	professional	fees.

• Expense	related	to	costs	associated	with	asset	

impairments	which	is	reflected	in	other	expense.

Settlement	of	the	obligations	arising	from	current	
initiatives	will	be	funded	from	operating	cash	flows.	

Total	expense	recognized	for	the	year	ended	December	
31,	2019	is	presented	in	the	table	below:

Table	8.25.1

RESTRUCTURING,	REPOSITIONING,	&	EFFICIENCY	EXPENSES

(Dollars	in	millions)

Personnel	expense

Legal	and	professional	fees

Net	occupancy	expense

Other

Total	restructuring,	repositioning,	and	efficiency	charges

Year	Ended	December	31,	2019

$	

$	

11	

16	

1	

12	

40	

	 209

2021 FORM 10-K ANNUAL REPORT

	
	
	
    
Table of Contents

NOTE	26—PARENT	COMPANY	FINANCIAL	INFORMATION

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Note 26—Parent Company Financial Information 

Following	are	statements	of	the	parent	company:

Parent Company Balance Sheets
Balance	Sheets
(Dollars	in	millions)
Assets:
Cash

Notes	receivable

Investments	in	subsidiaries:

Bank

Non-bank

Other	assets

Total	assets
Liabilities	and	equity:
Accrued	employee	benefits	and	other	liabilities

Term	borrowings

Total	liabilities

Total	equity

Total	liabilities	and	equity

Parent Company Statements of Income 

(Dollars	in	millions)

Dividend	income:

Bank

Non-bank

Total	dividend	income

Other	income	(loss)

Total	income

Provision	(provision	credit)	for	credit	losses

Interest	expense	-	term	borrowings

Personnel	and	other	expense

Total	expense

Income	before	income	taxes

Income	tax	benefit

Income	before	equity	in	undistributed	net	income	of	subsidiaries

Equity	in	undistributed	net	income	(loss)	of	subsidiaries:

Bank

Non-bank

Net	income	attributable	to	the	controlling	interest

$	

December	31,

2021

2020

$	

$	

$	

$	

724	 $	
3	

8,381	

65	

291	
9,464	 $	

321	 $	
944	

1,265	

8,199	
9,464	 $	

2021

Year	Ended	December	31,
2020

2019

$	

770	 $	
—	

770	

(26)	

744	

—	

31	

89	

120	

624	

(35)	

659	

332	

8	
999	 $	

180	 $	

—	

180	

—	

180	

—	

39	

54	

93	

87	

(18)	

105	

736	

4	

845	 $	

827	

3	

8,176	

88	

274	

9,368	

322	

1,034	

1,356	

8,012	

9,368	

345	

1	

346	

1	

347	

(1)	

31	

53	

83	

264	

(19)	

283	

160	

(2)	

441	

	 210

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
Table of Contents

NOTE	26—PARENT	COMPANY	FINANCIAL	INFORMATION

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Parent Company Statements of Cash Flows

(Dollars	in	millions)

Operating	activities:

Net	income

2021

2020

2019

$	

999	 $	

845	 $	

Less	undistributed	net	income	of	subsidiaries

Income	before	undistributed	net	income	of	subsidiaries
Adjustments	to	reconcile	income	to	net	cash	provided	by	operating	
activities:

				Depreciation,	amortization,	and	other

				(Gain)	loss	on	derivative	transactions

				Deferred	income	tax	expense

				Stock-based	compensation	expense

				Loss	on	extinguishment	of	debt

				Other	operating	activities,	net

Total	adjustments

Net	cash	provided	by	operating	activities

Investing	activities:

Proceeds	from	sales	and	prepayments	of	securities	

Purchases	of	securities

(Investment	in)	return	on	subsidiary

Cash	received	for	business	combination,	net

Net	cash	provided	by	(used	in)	investing	activities

Financing	activities:

Proceeds	from	issuance	of	preferred	stock

Call	of	preferred	stock

Cash	dividends	paid	-	preferred	stock

Common	stock:

				Stock	options	exercised				

				Cash	dividends	paid

				Repurchase	of	shares

Proceeds	from	issuance	of	term	borrowings

Repayment	of	term	borrowings

Other	financing	activities,	net

Net	cash	provided	by	(used	in)	financing	activities

Net	increase	(decrease)	in	cash	and	cash	equivalents

Cash	and	cash	equivalents	at	beginning	of	year

Cash	and	cash	equivalents	at	end	of	year

Total	interest	paid

Income	taxes	received	from	subsidiaries

340	
659	

—	

—	

8	

43	

26	

(11)	

66	

725	

3	

(10)	

8	

—	

1	

145	

(100)	 	

(33)	

28	

(333)	

(416)	

—	

(120)	

—	

(829)	

(103)	

827	

724	 $	
35	 $	

28	

740	
105	

—	

4	

5	

32	

—	

21	

62	

167	

—	

(5)	

(2)	

103	

96	

144	

—	

(17)	

7	

(222)	

(4)	

795	

(500)	

(8)	

195	

458	

369	

827	 $	

33	 $	

33	

$	

$	

441	

158	
283	

(1)	

—	

4	

22	

—	

28	

53	

336	

1	

—	

—	

—	

1	

—	

—	

(6)	

9	

(171)	

(134)	

—	

—	

—	

(302)	

35	

334	

369	

29	

43	

	 211

2021 FORM 10-K ANNUAL REPORT

	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
    
Table of Contents

NOTE	27—SUBSEQUENT	EVENTS

ITEM	8.	FINANCIAL	STATEMENTS	&	SUPPLEMENTARY	DATA

Following	the	completion	of	the	First	Holding	Company	
Merger,	at	such	time	as	determined	by	TD,	First	Horizon	
Bank	and	TD	Bank,	N.A.,	a	national	banking	association	
(“TDBNA”)	will	merge,	with	TDBNA	surviving	as	a	
subsidiary	of	TD-US	(the	“Bank	Merger”	and	together	with	
the	Holding	Company	Mergers,	the	“Proposed	TD	
Merger”).

In	connection	with	the	execution	of	the	TD	Merger	
Agreement,	TD	has	agreed	to	purchase	from	FHN	shares	
of	non-voting	Perpetual	Convertible	Preferred	Stock,	
Series	G,	a	new	series	of	preferred	stock	of	FHN	(the	
“Series	G	Convertible	Preferred	Stock”)	in	a	private	
placement	transaction	having	an	aggregate	liquidation	
preference	and	purchase	price	of	approximately	$493.5	
million,	pursuant	to	a	securities	purchase	agreement	
between	FHN	and	TD	entered	into	concurrently	with	the	
execution	and	delivery	of	the	TD	Merger	Agreement.	The	
Series	G	Convertible	Preferred	Stock	is	convertible	into	up	
to	4.9%	of	the	outstanding	shares	of	Company	Common	
Stock	in	certain	circumstances,	including	the	closing	of	the	
Proposed	TD	Merger.	

Merger	and	integration	expenses	related	to	the	Proposed	
TD	Merger	will	be	recorded	in	FHN’s	Corporate	segment.	
No	such	expenses	were	recognized	during	2021.

Note 27—Subsequent Events

2022	Merger	Agreement	with	Toronto-Dominion	Bank

On	February	27,	2022,	FHN	entered	into	an	Agreement	
and	Plan	of	Merger	(the	“TD	Merger	Agreement”)	with	
The	Toronto-Dominion	Bank,	a	Canadian	chartered	bank	
(“TD”),	TD	Bank	US	Holding	Company,	a	Delaware	
corporation	and	indirect,	wholly	owned	subsidiary	of	TD	
(“TD-US”),	and	Falcon	Holdings	Acquisition	Co.,	a	
Delaware	corporation	and	wholly	owned	subsidiary	of	TD-
US	(“Merger	Sub”).

Pursuant	to	the	TD	Merger	Agreement,	FHN	and	Merger	
Sub	will	merge	(the	“First	Holding	Company	Merger”),	
with	FHN	continuing	as	the	surviving	entity	in	the	merger.		
Following	the	First	Holding	Company	Merger,	at	the	
election	of	TD,	FHN	and	TD-US	will	merge	(the	“Second	
Holding	Company	Merger”	and,	together	with	the	First	
Holding	Company	Merger,	the	“Holding	Company	
Mergers”),	with	TD-US	continuing	as	the	surviving	entity	in	
the	merger.	

Upon	the	terms	and	subject	to	the	conditions	set	forth	in	
the	TD	Merger	Agreement,	each	share	of	FHN	common	
stock,	par	value	$0.625	per	share,	(“Company	Common	
Stock”),	issued	and	outstanding	immediately	prior	to	the	
effective	time	of	the	First	Holding	Company	Merger	(the	
“First	Effective	Time”)	will	be	converted	into	the	right	to	
receive	$25.00	(USD)	per	share	in	cash,	without	interest.	If	
the	transaction	does	not	close	on	or	before	November	27,	
2022,	shareholders	will	receive	an	additional	$0.65	per	
share	of	Company	Common	Stock	on	an	annualized	basis	
(or	approximately	5.4	cents	per	month)	for	the	period	
from	November	28,	2022	through	the	day	immediately	
prior	to	the	closing.	Each	outstanding	share	of	FHN’s	
preferred	stock,	series	B,	C,	D,	E	and	F,	will	remain	issued	
outstanding	in	connection	with	the	First	Holding	Company	
Merger.	If	TD	elects	to	effect	the	Second	Holding	Company	
Merger,	at	the	effective	time	of	the	Second	Holding	
Company	Merger,	each	outstanding	share	of	FHN’s	
preferred	stock	will	be	converted	into	a	share	of	a	newly	
created,	corresponding	series	of	TD-US	having	terms	as	
described	in	the	Merger	Agreement.

	 212

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ITEM	9.	ACCOUNTANTS,	ITEM	9A.	CONTROLS	&	PROCEDURES,	ITEM	9B.	OTHER	INFO,	AND	ITEM	9C.	FOREIGN	INSPECTIONS

Table	of	Contents

Item 9.  Changes in and Disagreements with 

Accountants on Accounting and 
Financial Disclosure

Not	applicable.

Item 9A. Controls and Procedures

Evaluation of Disclosure Controls & Procedures

Our	management,	with	the	participation	of	our	Chief	
Executive	Officer	and	Chief	Financial	Officer,	has	evaluated	
the	effectiveness	of	our	disclosure	controls	and	
procedures	(as	defined	in	Exchange	Act	Rule	13a-15(e))	as	
of	the	end	of	the	period	covered	by	this	report.	Based	on	

that	evaluation,	the	Chief	Executive	Officer	and	the	Chief	
Financial	Officer	have	concluded	that	our	disclosure	
controls	and	procedures	were	effective	as	of	the	end	of	
the	period	covered	by	this	report.	

Reports on Internal Control over Financial Reporting

The	report	of	management	required	by	Item	308(a)	of	
Regulation	S-K	appears	at	page	109,	and	the	attestation	
report	required	by	Item	308(b)	of	Regulation	S-K	appears	

starting	at	page	110,	of	our	2021	Financial	Statements	
(Item	8).	Both	are	incorporated	herein	by	this	reference.	

Changes in Internal Control over Financial Reporting

There	have	not	been	any	changes	in	our	internal	control	
over	financial	reporting	during	our	fourth	fiscal	quarter	
that	have	materially	affected,	or	are	reasonably	likely	to	

materially	affect,	our	internal	control	over	financial	
reporting.

Item 9B. Other Information

Not	applicable.

Item 9C. Disclosure Regarding Foreign 

Jurisdictions that Prevent Inspections

Not	applicable.

	 213

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

ITEM	10.	DIRECTORS	&	EXECUTIVE	OFFICERS

PART  III

Item 10. Directors and Executive Officers of the 

Registrant

Required Item 10 Information

In	2021	there	were	no	material	amendments	to	the	
procedures,	described	in	our	2022	Proxy	Statement	under	
the	caption	Shareholder	Recommendations	of	Director	
Nominees;	Shareholder	Nominations,	by	which	security	
holders	may	recommend	nominees	to	our	Board	of	
Directors.	

Our	bylaws	contain	a	process,	if	certain	conditions	are	
met,	for	a	shareholder	to	nominate	a	person	for	election	
to	the	Board	in	advance	of	an	annual	meeting,	and	to	
require	us	to	include	that	nomination	in	our	annual	
meeting	proxy	statement.	Additional	information	
regarding	this	process	is	available	in	our	2022	Proxy	
Statement	under	the	captions	Shareholder	
Recommendations	of	Director	Nominees;	Shareholder	
Nominations	and	2023	Annual	Meeting—Proposal	&	
Nomination	Deadlines,	which	information	is	incorporated	
herein	by	reference.

Our	Board	of	Directors	has	adopted	a	Code	of	Ethics	for	
Senior	Financial	Officers	that	applies	to	the	Chief	
Executive	Officer,	Chief	Financial	Officer,	and	Chief	

Accounting	Officer	and	also	applies	to	all	professionals	
serving	in	the	financial,	accounting,	or	audit	areas	of	FHN	
and	its	subsidiaries.	A	copy	of	the	Code	has	been	filed	or	
incorporated	by	reference	as	Exhibit	14	to	this	report	and	
is	posted	on	our	current	internet	website	(at	
www.firsthorizon.com:	click	on	“Investor	Relations,”	at	the	
bottom	of	the	web	page,	then	hover	over	the	Investor	
Relations	box	at	the	top	of	the	page,	then	hover	over	
“Corporate	Governance,”	and	lastly	click	on	“Governance	
Documents.”)	A	paper	copy	of	the	Code	is	available	
without	charge	upon	written	request	addressed	to	our	
Corporate	Secretary	at	our	main	office,	165	Madison	
Avenue,	Memphis,	Tennessee	38103.	We	intend	to	satisfy	
our	disclosure	obligations	under	Item	5.05	of	Form	8-K	
related	to	Code	amendments	or	waivers	by	posting	such	
information	on	our	internet	website,	the	address	for	
which	is	listed	in	this	paragraph	above.	

Other	information	required	by	this	Item	related	to	the	
topics	mentioned	in	Table	10.1	is	incorporated	herein	by	
reference	to	the	disclosures	indicated	in	the	Table.

Table	10.1

ITEM	10	TOPICS	TABLE

Item	10	Topics

Incorporated	Disclosures

Directors	and	nominees	for	director	of	FHN,	the	
Audit	Committee	of	our	Board	of	Directors,	
members	of	the	Audit	Committee,	and	Audit	
Committee	financial	experts

Executive	officers

In	our	2022	Proxy	Statement:	Independence	&	Categorical	Standards,	Committee	
Charters	&	Composition,	Audit	Committee,	and	Vote	Item	1—Election	of	Directors	
(excluding	the	Audit	Committee	Report	and	the	statements	regarding	the	
existence	and	location	of	the	Audit	Committee’s	charter)
In	the	Supplemental	Part	I	Information	following	Item	4	of	this	report:	Executive	
Officers	of	the	Registrant,	beginning	on	page	56

Compliance	with	Section	16(a)	of	the	Securities	
Exchange	Act	of	1934

In	our	2022	Proxy	Statement:	Delinquent	Section	16(a)	Reports

	 214

2021 FORM 10-K ANNUAL REPORT

    
ITEM	10.	DIRECTORS	&	EXECUTIVE	OFFICERS

Table	of	Contents

First Horizon Directors

Table	10.2

Harry	V.	Barton,	Jr.
Age	67
CPA	and	Owner,
Barton	Advisory	Services,	LLC,
an	investment	advisory	firm

John	N.	Casbon
Age	73
Executive	Vice	President,
First	American	Title	Insurance	
Company,
a	title	insurance	company
William	H.	Fenstermaker
Age	73
Chairman	and	CEO,
C.H.	Fenstermaker	and	Associates,	
LLC,
a	surveying,	mapping,	engineering,	
and	environmental	consulting	
company
Rick	E.	Maples
Age	63
Retired	Co-Head	of	Investment	
Banking,
Stifel,	Nicolaus	and	Company,	
Incorporated,
a	financial	services	company
E.	Stewart	Shea	III
Age	70
Private	Investor

Rosa	Sugrañes
Age	64
Founder	and	former
Chief	Executive	Officer,
Iberia	Tiles,
a	ceramic	tile	distributor

OUR	BOARD	OF	DIRECTORS
(at	February	20,	2022)

Kenneth	A.	Burdick
Age	63
Retired	Executive	Vice	President,
Products	and	Markets,
Centene	Corporation,
a	healthcare	services	company
John	C.	Compton
Age	60
Partner,
Clayton,	Dubilier	&	Rice,	LLC
a	private	equity	firm

D.	Bryan	Jordan
Age	60
President	and
Chief	Executive	Officer,
First	Horizon	Corporation,
a	financial	services	company

Vicki	R.	Palmer
Age	68
President,
The	Palmer	Group,	LLC
a	general	consulting	firm

Cecelia	D.	Stewart
Age	63
Retired	President,	U.S.	Consumer	&	
Commercial	Banking,
Citigroup,	Inc.
a	financial	services	company

Daryl	G.	Byrd
Age	67
Executive	Chairman	of	the	Board,
First	Horizon	Corporation,
a	financial	services	company

Wendy	P.	Davidson
Age	52
President-Americas	for	the	
Performance	Nutrition	segment	of	
Ireland-based	Glanbia	plc,
a	global	nutrition	company
J.	Michael	Kemp,	Sr.
Age	51
Founder	and	Chief	Executive	Officer,
Kemp	Management	Solutions,
a	program	management	and
consulting	firm

Colin	V.	Reed
Age	74
Chairman	of	the	Board	and
Chief	Executive	Officer,
Ryman	Hospitality	Properties,	Inc.
a	real	estate	investment	trust

Rajesh	Subramaniam
Age	56
President	and
Chief	Operating	Officer,
FedEx	Corporation
a	provider	of	transportation,	e-
commerce,	and	business	services
R.	Eugene	Taylor
Age	74
Retired	Chairman	of	the	Board	and
Chief	Executive	Officer,
Capital	Bank	Financial	Corp.,
a	financial	services	company

	 215

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

Item 11. Executive Compensation

ITEM	11.	EXECUTIVE	COMPENSATION

The	information	called	for	by	this	Item	is	incorporated	
herein	by	reference	to	the	following	sections	of	our	2022	
Proxy	Statement:	Compensation	Committee,	
Compensation	Committee	Interlocks	&	Insider	
Participation,	Director	Compensation,	Compensation	
Discussion	&	Analysis,	Recent	Compensation,	Post-
Employment	Compensation,	Pay	Ratio	of	CEO	to	Median	
Employee,	and	each	Appendix	to	our	Proxy	Statement	
referenced	in	those	sections.

The	sub-section	of	our	2022	Proxy	Statement	captioned	
Compensation	Risk,	within	the	Compensation	Committee	
section,	provides	information	concerning	our	
management	of	certain	risks	associated	with	our	

compensation	policies	and	practices.	We	do	not	believe	
those	risks	are	reasonably	likely	to	have	a	material	
adverse	effect	upon	us;	accordingly,	we	do	not	believe	
that	information	is	required	to	be	provided	in	this	Item.

The	information	required	by	Item	407(e)(5)	of	Regulation	
S-K	is	provided	in	our	2022	Proxy	Statement	within	the	
Compensation	Committee	section	under	the	sub-section	
captioned	Compensation	Committee	Report.		As	permitted	
by	the	instructions	for	that	Item,	the	information	under	
that	sub-section	is	not	“filed”	with	this	report.	

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Table	of	Contents

ITEM	12.	SECURITY	OWNERSHIP	&	RELATED	STOCKHOLDER	MATTERS

Item 12. Security Ownership of Certain 

Beneficial Owners and Management and 
Related Stockholder Matters

Securities Authorized for Issuance under Equity Compensation 
Plans

Equity Compensation Plan Information

Table	12.1	provides	information	as	of	December	31,	2021	
regarding	shares	of	our	common	stock	that	may	be	issued	
under	the	following	plans:

• 2021	Incentive	Plan	("2021	Plan")

• Equity	Compensation	Plan	(“ECP”)	

• IBERIABANK	Corporation	2019	Stock	Incentive	Plan	

("SIP")

• 1997	Employee	Stock	Option	Plan	(“1997	Plan”)

• 2002	and	1996	Bank	Director	and	Advisory	Board	
Member	Deferral	Plans	(“Advisory	Board	Plans”)

Table	12.1

• 2000	Non-employee	Directors’	Deferred	

Compensation	Stock	Option	Plan	(“2000	Directors’	
Plan”)

• The	following	IBERIABANK	Corporation	plans	

(together	with	the	SIP,	the	“IBKC	Plans”):	2016	Stock	
Incentive	Plan;	and	Amended	and	Restated	2010	
Stock	Incentive	Plan

• The	following	Capital	Bank	Financial	Corp.	plans	(“CBF	
Plans”):	Capital	Bank	Financial	Corp.	2013	Omnibus	
Compensation	Plan;	and	FNB	United	Corp.	2012	
Incentive	Plan

EQUITY	COMPENSATION	PLAN	INFORMATION
As	of	December	31,	2021

A

B

C

Number	of	Securities	to	be	
Issued	upon	Exercise	of	
Outstanding	Options	(1)

Weighted	Average	
Exercise	Price	of	
Outstanding	Options	(1)

Number	of	Securities	
Remaining	Available	for	
Future	Issuance	under	
Equity		Compensation	
Plans	(excluding	securities	
reflected	in	Col.	A)	

4,741,471	 (3)

239,458	 (4)

4,980,929	

$15.56

$20.75

$15.81

12,329,976	

—	 (4)

12,329,976	

Plan	Category
Equity	Compensation	Plans	Approved	
by	Shareholders	(2)

Equity	Compensation	Plans	Not	
Approved	by	Shareholders	(4)

Totals	for	A	&	C,	wtd	avg	for	B

(1)	 The	numbers	of	shares	covered	by	stock	options	and	the	related	option	prices	have	been	adjusted	proportionately	to	reflect	the	estimated	economic	

effects	of	dividends	distributed	in	common	stock	effective	October	1,	2008	through	January	1,	2011.	The	cumulative	compound	adjustment	factor	related	
to	those	dividends	is	20.038%.

(2)	 Consists	of	the	2021	Plan,	the	ECP,	the	2000	Directors’	Plans,	the	IBKC	Plans,	and	the	CBF	Plans.	The	2021	Plan	was	approved	by	shareholders	in	2021	and	
remains	active.	The	number	of	shares	in	Column	C	is	entirely	under	the	2021	Plan;	as	provided	in	the	2021	Plan,	the	Col.	C	number	includes	the	new/
additional	shares	originally	authorized	under	the	2021	Plan	along	with	shares	underlying	ECP	awards	that	have	been	forfeited	or	cancelled	since	the	2021	
Plan	was	approved	by	shareholders,	net	of	shares	underlying	2021	Plan	awards	that	are	outstanding	or	have	been	paid.	The	ECP	initially	was	approved	by	
shareholders	in	2003,	most	recently	was	re-approved	in	2016,	and	has	terminated.	The	2000	Directors’	Plan	was	approved	by	shareholders	in	2000,	and	
has	terminated.	The	IBKC	Plans	were	approved	by	IBKC's	shareholders	in	2005,	2020,	2011,	2014,	2016,	and	2019,	and	all	have	terminated.	FHN	and	IBKC	
closed	a	merger-of-equals	transaction	in	2020,	as	a	result	of	which	FHN	became	the	plan	sponsor	for	the	IBKC	Plans	and	their	awards.	The	CBF	Plans	were	
approved	by	shareholders	of	CBF	or	certain	other	predecessor	companies,	and	all	have	terminated.		FHN	merged	with	CBF	in	2017,	as	a	result	of	which	
FHN	became	the	plan	sponsor	for	the	CBF	Plans	and	their	awards."Terminated"	means	no	new	awards	may	be	granted	under	the	plan.

(3)	 Consists	entirely	of	outstanding	options	issued	under	terminated	plans	approved	by	shareholders,	30,733	of	which	directly	or	indirectly	were	issued	in	

connection	with	non-employee	director	cash	deferrals	of	approximately	$0.3	million.	

(4)	 Consists	of	the	1997	Plan	and	the	Advisory	Board	Plans,	all	of	which	have	terminated.	These	outstanding	options	were	issued	directly	or	indirectly	in	

connection	with	associate	and	advisory	board	cash	deferrals	of	approximately	$2.6	million.

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ITEM	12.	SECURITY	OWNERSHIP	&	RELATED	STOCKHOLDER	MATTERS

Table	of	Contents

Only	the	2021	Plan	permits	new	awards	to	be	granted;	all	
other	plans	have	terminated.	At	December	31,	2021,	there	
were	no	shares	issuable	upon	exercise	of	outstanding	
options	under	the	2021	Plan,	and	the	total	number	of	
shares	issuable	upon	exercise	of	outstanding	options	
under	the	terminated	plans	was	4,980,929	shares.

Shares	covered	by	outstanding	options	are	shown	in	
column	A	of	Table	12.1.	Outstanding	equity	awards	other	
than	options	("full-value	awards"),	consisting	of	unpaid	
stock	units	and	restricted	stock,	are	not	included	in	any	
column	in	that	Table.	In	total,	9,296,888	shares	are	
covered	by	unpaid	full-value	awards,	all	granted	under	the	
2021	Plan,	the	ECP,	or	the	SIP.Of	those,	8,714,844	are	
covered	by	unvested	awards,	and	582,044	are	covered	by	
awards	that	have	vested	but	are	subject	to	an	unfulfilled	
mandatory	deferral	period.	In	addition,	there	are	227,830	
fully	vested	deferral	stock	units	outstanding	that	are	the	
result	of	previously	exercised	options	under	terminated	
plans	for	which	the	receipt	of	the	shares	was	deferred	by	
the	associate.

Column	C	of	Table	12.1	presents	the	total	number	of	
shares	available	for	new	awards	under	the	2021	Plan	at	
December	31,	2021,	assuming	eventual	full	exercise	or	
vesting	of	all	shares	covered	by	awards	outstanding	on	
that	date.	The	2021	Plan	permits	the	grant	of	options	and	
full-value	awards,	as	well	as	stock	appreciation	rights	
(none	of	which	have	been	granted).

Of	the	options	outstanding	at	December	31,	2021	(the	
total	under	column	A),	approximately	5%	were	issued	
directly	or	indirectly	in	connection	with	associate	and	
director	cash	deferral	elections.	We	received	over	many	
years	a	total	of	approximately	$2.5	million	in	associate	
cash	deferrals	and	$0.4	million	in	non-employee	director	
and	advisory	board	retainer	and	meeting	fee	deferrals	
related	to	outstanding	deferral	options.	The	opportunity	
to	defer	portions	of	compensation	in	exchange	for	options	
has	not	been	offered	to	associates,	directors,	or	advisory	
board	members	since	2004.

Description of Equity Compensation Plans Not Approved by Shareholders

The	1997	Plan

The	Advisory	Board	Plans

The	1997	Plan	was	adopted	by	the	Board	of	Directors	in	
1996	and	terminated	in	2007.	The	1997	Plan	authorized	
the	grant	of	nonqualified	stock	options.	

The	Advisory	Board	Plans	were	adopted	by	the	Board	of	
Directors	in	2001	and	1996,	and	terminated	in	2005	and	
2002,	respectively.	

Options	were	granted	under	the	1997	Plan	prior	to	its	
termination	pursuant	to	a	management	option	program,	
covering	a	wide	range	of	management-level	associates.	
The	last	management	options	granted	under	the	1997	
Plan,	with	seven-year	terms,	expired	in	2014.	However,	
prior	to	2005	certain	associates	could	elect	to	defer	a	
portion	of	their	annual	compensation	into	stock	options	
under	the	1997	Plan.	Many	deferral	options	had	20-year	
terms,	and	they	are	the	only	options	still	outstanding	
under	the	1997	Plan.

All	deferral	options	granted	under	the	1997	Plan	had	an	
exercise	price	discounted	from	grant	date	fair	market	
value:	the	aggregate	exercise	price	plus	the	aggregate	
compensation	foregone	equaled	the	aggregate	grant	date	
fair	market	value.	Options	could	be	exercised	using	shares	
of	FHN	stock	to	pay	the	option	price.	When	an	option	was	
exercised	with	shares,	the	option	holder	sometimes	
received	a	new	(reload)	option	grant	priced	at	then-
current	market	(without	a	discount),	covering	the	
remainder	of	the	deferral	option's	term.

As	of	December	31,	2021,	options	covering	232,254	shares	
of	our	common	stock	were	outstanding	under	the	1997	
Plan,	no	shares	remained	available	for	future	option	
grants,	and	options	covering	21,027,943	shares	had	been	
exercised	during	the	life	of	the	plan.	The	1997	Plan	was	
filed	most	recently	as	Exhibit	10.2(d)	in	our	Form	10-Q	for	
the	quarter	ended	June	30,	2009.

Options	granted	under	the	Advisory	Board	Plans	were	
granted	only	to	regional	and	advisory	board	members,	or	
to	directors	of	certain	bank	affiliates,	in	any	case	who	
were	not	associates.	The	options	were	granted	in	lieu	of	
the	participants	receiving	retainers	or	attendance	fees	for	
bank	board	and	advisory	board	meetings.	The	number	of	
shares	subject	to	grant	equaled	the	amount	of	fees/
retainers	earned	divided	by	one	half	of	the	fair	market	
value	of	one	share	of	common	stock	on	the	date	of	the	
option	grant.	The	exercise	price	plus	the	amount	of	fees	
foregone	equaled	the	fair	market	value	of	the	stock	on	the	
grant	date.	The	options	were	vested	at	the	grant	date.	
Those	granted	on	or	before	January	2,	2004	had	terms	of	
twenty	years,	and	are	the	only	options	still	outstanding.	

As	of	December	31,	2021,	options	covering	7,204	shares	of	
our	common	stock	were	outstanding	under	the	Advisory	
Board	Plans,	no	shares	remained	available	for	future	
option	grants,	and	options	covering	90,097	shares	had	
been	exercised	during	the	life	of	the	Plans.	The	Advisory	
Board	Plans	were	included	as	Exhibits	10.1(f)	and	10.1(g)	
to	our	Form	10-Q	for	the	quarter	ended	June	30,	2009.	At	
the	time	this	report	is	filed,	all	options	outstanding	under	
the	1996	Advisory	Board	Plan	at	December	31,	2021	have	
either	expired	or	been	exercised.

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Table	of	Contents

ITEM	12.	SECURITY	OWNERSHIP	&	RELATED	STOCKHOLDER	MATTERS

Beneficial Ownership of Corporation Stock

The	information	required	for	this	Item	pursuant	to	Item	
403(a)	and	(b)	of	Regulation	S-K	is	presented	in	our	2022	
Proxy	Statement	under	the	heading	Stock	Ownership	

Information.	That	information	is	incorporated	into	this	
Item	by	reference.

Change in Control Arrangements

We	are	not	aware	of	any	arrangements	which	may	result	in	a	change	in	control	of	First	Horizon	Corporation.

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ITEM	13.	CERTAIN	RELATIONSHIPS	&	RELATED	TRANSACTIONS		AND		ITEM	14.	PRINCIPAL	ACCOUNTANT	FEES	&	SERVICES

Table	of	Contents

Item 13. Certain Relationships and Related 

Transactions

The	information	called	for	by	this	Item	is	presented	in	the	
following	sections	of	our	2022	Proxy	Statement:	
Independence	&	Categorical	Standards;	Related	Party	
Transaction	Procedures;	and	Transactions	with	Related	
Persons.	That	information	is	incorporated	into	this	Item	by	

reference.	Our	independent	directors	and	nominees	are	
identified	in	the	first	paragraph	of	the	Independence	
discussion	within	the	Independence	&	Categorical	
Standards	section	of	our	2022	Proxy	Statement.	

Item 14. Principal Accountant Fees and Services

The	Audit	Committee	of	the	Board	of	Directors	has	a	
policy	providing	for	pre-approval	of	all	audit	and	non-audit	
services	to	be	performed	by	our	registered	public	
accounting	firm	that	performs	the	audit	of	our	
consolidated	financial	statements	(our	“Auditor”).	Services	
either	may	be	approved	in	advance	by	the	Audit	
Committee	specifically	on	a	case-by-case	basis	(“specific	
pre-approval”)	or	may	be	approved	in	advance	(“advance	
pre-approval”).	Advance	pre-approval	requires	the	
Committee	to	identify	in	advance	the	specific	types	of	
service	that	may	be	provided	and	the	fee	limits	applicable	
to	such	types	of	service,	which	limits	may	be	expressed	as	
a	limit	by	type	of	service	or	by	category	of	services.	All	
requests	to	provide	services	that	have	been	pre-approved	
in	advance	must	be	submitted	to	the	Chief	Accounting	
Officer	prior	to	the	provision	of	such	services	for	a	
determination	that	the	service	to	be	provided	is	of	the	
type	and	within	the	fee	limit	that	has	been	pre-approved.	
Unless	the	type	of	service	to	be	provided	by	our	Auditor	
has	received	advance	pre-approval	under	the	policy	and	
the	fee	for	such	service	is	within	the	limit	pre-approved,	
the	service	will	require	specific	pre-approval	by	the	
Committee.	

The	terms	of	and	fee	for	the	annual	audit	engagement	
must	receive	the	specific	pre-approval	of	the	Committee.	
“Audit,”	“Audit-related,”	“Tax,”	and	“All	Other”	services,	
as	those	terms	are	defined	in	the	policy,	have	the	advance	
pre-approval	of	the	Committee,	but	only	to	the	extent	

those	services	have	been	specified	by	the	Committee	and	
only	in	amounts	that	do	not	exceed	the	fee	limits	specified	
by	the	Committee.	Such	advance	pre-approval	is	to	be	for	
a	term	of	12	months	following	the	date	of	pre-approval	
unless	the	Committee	specifically	provides	for	a	different	
term.	Unless	the	Committee	specifically	determines	
otherwise,	the	aggregate	amount	of	the	fees	pre-
approved	for	All	Other	services	for	the	fiscal	year	must	not	
exceed	seventy-five	percent	(75%)	of	the	aggregate	
amount	of	the	fees	pre-approved	for	the	fiscal	year	for	
Audit	services,	Audit-related	services,	and	those	types	of	
Tax	services	that	represent	tax	compliance	or	tax	return	
preparation.	The	policy	delegates	the	authority	to	pre-
approve	services	to	be	provided	by	our	Auditor,	other	
than	the	annual	audit	engagement	and	any	changes	
thereto,	to	the	chair	of	the	Committee.	The	chair	may	not,	
however,	make	a	determination	that	causes	the	75%	limit	
described	above	to	be	exceeded.	Any	service	pre-
approved	by	the	chair	will	be	reported	to	the	Committee	
at	its	next	regularly	scheduled	meeting.	

Information	regarding	fees	billed	to	FHN	by	our	Auditor,	
KPMG	LLP,	for	the	two	most	recent	fiscal	years	is	
incorporated	herein	by	reference	to	the	section	of	our	
2022	Proxy	Statement	captioned	Vote	Item	2—Auditor	
Ratification.	No	services	were	approved	by	the	Audit	
Committee	pursuant	to	Rule	2-01(c)(7)(i)(C)	of	Regulation	
S-X.

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Table	of	Contents

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

PART  IV

Item 15. Exhibits and Financial Statement 

Schedules

Financial Statements & Related Reports

Our	consolidated	financial	statements,	the	notes	thereto,	
and	the	reports	of	management	and	independent	public	
accountants,	as	listed	below,	are	incorporated	herein	by	

reference	to	the	pages	of	2021	Financial	Statements	(Item	
8)	indicated	in	Table	15.1.	

Table	15.1

Item	8	Page
109
110
114
115
117
118
120
122

Statement,	Note,	or	Report	Incorporated	into	Item	15
Report	of	Management	on	Internal	Control	over	Financial	Reporting	
Reports	of	Independent	Registered	Public	Accounting	Firm
Consolidated	Balance	Sheets	as	of	December	31,	2021	and	2020
Consolidated	Statements	of	Income	for	the	years	ended	December	31,	2021,	2020,	and	2019
Consolidated	Statements	of	Comprehensive	Income	for	the	years	ended	December	31,	2021,	2020,	and	2019
Consolidated	Statements	of	Changes	in	Equity	for	the	years	ended	December	31,	2021,	2020,	and	2019
Consolidated	Statements	of	Cash	Flows	for	the	years	ended	December	31,	2021,	2020,	and	2019
Notes	to	the	Consolidated	Financial	Statements

Financial Statement Schedules

Not	applicable.

Exhibits

In	the	exhibit	table	that	follows:	the	“Filed	Here”	column	
denotes	each	exhibit	which	is	filed	or	furnished	(as	
applicable)	with	this	report;	the	“Mngt	Exh”	column	
denotes	each	exhibit	that	represents	a	management	
contract	or	compensatory	plan	or	arrangement	required	
to	be	identified	as	such;	the	“Furnished”	column	denotes	
each	exhibit	that	is	“furnished”	pursuant	to	18	U.S.C.	
Section	1350	or	otherwise,	and	is	not	“filed”	as	part	of	this	
report	or	as	a	separate	disclosure	document;	and	the	
phrase	“2021	named	executive	officers”	refers	to	those	
executive	officers	whose	2021	compensation	is	described	
in	our	2022	Proxy	Statement.	All	references	to	“First	
Horizon	National	Corporation”	or	to	"First	Tennessee	
National	Corporation"	refer	to	us,	under	previous	
corporate	names.

In	many	agreements	filed	as	exhibits,	each	party	makes	
representations	and	warranties	to	other	parties.	Those	
representations	and	warranties	are	made	only	to	and	for	
the	benefit	of	those	other	parties	in	the	context	of	a	
business	contract.	Exceptions	to	such	representations	and	
warranties	may	be	partially	or	fully	waived	by	such	parties,	
or	not	enforced	by	such	parties,	in	their	discretion.	No	
such	representation	or	warranty	may	be	relied	upon	by	
any	other	person	for	any	purpose.

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Table	of	Contents

Table	15.2

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

10-K	EXHIBIT	TABLE

Exh	
No

2.1

3.1

3.2

4.1

4.2

4.3

4.4

4.5

4.6

4.7

4.8

4.9

Description	of	Exhibit	to	this	10-K	Report
Corporate	Exhibits
Agreement	and	Plan	of	Merger	dated	as	of	February	27,	2022,	
between	FHN,	The	Toronto-Dominion	Bank,	TD	Bank	US	Holding	
Company,	and	Falcon	Holdings	Acquisition	Co.	[conformed	copy]
Amended	and	Restated	Charter	of	First	Horizon	Corporation
Bylaws	of	First	Horizon	Corporation,	as	amended	and	restated	
effective	November	30,	2020
Deposit	Agreement,	dated	as	of	July	1,	2020,	by	and	among	First	
Horizon	National	Corporation,	Equiniti	Trust	Company,	as	
depositary,	and	the	holders	from	time	to	time	of	the	depositary	
receipts	described	therein	[Series	B]
Form	of	Depositary	Receipt--Series	B	(included	as	part	of	Exhibit	
4.1	to	this	report)
Deposit	Agreement,	dated	as	of	July	1,	2020,	by	and	among	First	
Horizon	National	Corporation,	Equiniti	Trust	Company,	as	
depositary,	and	the	holders	from	time	to	time	of	the	depositary	
receipts	described	therein	[Series	C]
Form	of	Depositary	Receipt--Series	C	(included	as	part	of	Exhibit	
4.3	to	this	report)
Deposit	Agreement,	dated	as	of	July	1,	2020,	by	and	among	First	
Horizon	National	Corporation,	Equiniti	Trust	Company,	as	
depositary,	and	the	holders	from	time	to	time	of	the	depositary	
receipts	described	therein	[Series	D]
Form	of	Depositary	Receipt--Series	D	(included	as	part	of	Exhibit	
4.5	to	this	report)
Deposit	Agreement,	dated	as	of	May	28,	2020,	by	and	among	
First	Horizon	National	Corporation,	Equiniti	Trust	Company,	as	
depositary,	and	the	holders	from	time	to	time	of	the	depositary	
receipts	described	therein	[Series	E]

Form	of	certificate	representing	Series	E	Preferred	Stock
Form	of	Depositary	Receipt--Series	E	(included	as	part	of	Exhibit	
4.7	to	this	report)

4.10

Deposit	Agreement,	dated	as	of	May	3,	2021,	by	and	among	
First	Horizon	Corporation,	Equiniti	Trust	Company,	as	
depositary,	and	the	holders	from	time	to	time	of	the	depositary	
receipts	described	therein	[Series	F]

4.11 Form	of	certificate	representing	the	Series	F	Preferred	Stock
4.12 Form	of	Depositary	Receipt-Series	F	representing	the	Depositary	

Shares	(included	as	part	of	Exhibit	4.10	to	this	report)
Description	of	Securities	Registered	Pursuant	to	Section	12	of	
the	Securities	Exchange	Act	of	1934
FHN	agrees	to	furnish	to	the	Securities	and	Exchange	
Commission	upon	request	a	copy	of	each	instrument	defining	
the	rights	of	the	holders	of	the	senior	and	subordinated	long-
term	debt	of	FHN	and	its	consolidated	subsidiaries

Filed	
Here

Mngt	
Exh

Furn-
ished

Incorporated	by	Reference	to

Form Exh	No

Filing	Date

X

8-K

8-K

3.1

3.2

7/30/2021

12/1/2020

8-K

4.1

7/2/2020

8-K

4.1

7/2/2020

8-K

4.2

7/2/2020

8-K

4.2

7/2/2020

8-K

4.3

7/2/2020

8-K

4.3

7/2/2020

8-K

4.1

5/28/2020

8-K

8-K

8-K

8-K

8-K

10-Q
2Q21

4.2

4.1

5/28/2020

5/28/2020

4.1

5/03/2021

4.2

4.1

4.4

5/03/2021

5/03/2021

8/5/2021

Equity-Based	Award	Plans

2021	Incentive	Plan

Equity	Compensation	Plan	(as	amended	and	restated	April	26,	
2016)

IBERIABANK	Corporation	2019	Stock	Incentive	Plan

IBERIABANK	Corporation	2016	Stock	Incentive	Plan

X

X

X

X

Proxy	
2021
Proxy	
2016
10-K	
2020
10-K	
2020

App.	A

3/15/2021

App.	A

3/14/2016

10.1(b)

2/25/2021

10.1(c)

2/25/2021

	 222

2021 FORM 10-K ANNUAL REPORT

4.13

4.14

10.1	
(a)
10.1	
(b)
10.1	
(c)
10.1	
(d)

    
Table	of	Contents

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

Exh	
No
10.1	
(e)
10.1	
(f)
10.1	
(g)

10.2	
(a)
10.2	
(b)
10.2	
(c)
10.2	
(d)

10.3	
(a)
10.3	
(b)
10.3	
(c)
10.3	
(d)
10.3	
(e)
10.3	
(f)
10.3	
(g)
10.3	
(h)
10.3		
(i)
10.3		
(j)
10.3	
(k)

10.4	
(a)
10.4	
(b)
10.4	
(c)
10.4	
(d)
10.4	
(e)
10.4	
(f)
10.4	
(g)

Description	of	Exhibit	to	this	10-K	Report

IBERIABANK	Corporation	2010	Stock	Incentive	Plan

1997	Employee	Stock	Option	Plan,	as	restated	for	amendments	
through	December	15,	2008

2000	Non-Employee	Directors’	Deferred	Compensation	Stock	Option	
Plan,	as	restated	for	amendments	through	December	15,	2008

Performance-Based	Equity	Award	Documents

Form	of	Grant	Notice	for	Special	Retention	Stock	Units	[2016]

Form	of	Grant	Notice	for	Executive	Performance	Stock	Units	
[2019]
Form	of	Grant	Notice	for	Executive	Performance	Stock	Units	
[2020]
Form	of	Grant	Notice	for	Executive	Performance	Stock	Units	
[2021]
Stock	Option	Award	Documents
Form	of	Agreement	to	Defer	Receipt	of	Shares	Following	Option	
Exercise

Form	of	Stock	Option	Grant	Notice

First	Tennessee	Stock	Option	Enhancement	Program

Form	of	Grant	Notice	for	Executive	Stock	Options	[2015]

Form	of	Grant	Notice	for	Executive	Stock	Options	[2016]

Form	of	Grant	Notice	for	Special	Retention	Stock	Options	[2016]

Form	of	Grant	Notice	for	Executive	Stock	Options	[2017]

Form	of	Grant	Notice	for	Executive	Stock	Options	[2018]

Form	of	Grant	Notice	for	Executive	Stock	Options	[2019]

Form	of	Grant	Notice	for	Executive	Stock	Options	[2020]

Form	of	IBERIABANK	Corporation	Stock	Option	Agreement

Other	Equity-Based	Award	Documents

Form	of	Grant	Notice	for	Executive	Restricted	Stock	Units	[2019]

Form	of	Grant	Notice	for	Executive	Restricted	Stock	Units	[2020]

Form	of	Grant	Notice	for	Executive	Restricted	Stock	Units	[2021]	

Form	of	Grant	Notice	for	Executive	Restricted	Stock	Units	-	
Special	Bonus-Driven	Award	[2021]
Form	of	Grant	Notice	for	Special	Executive	Restricted	Stock:	
IBKC	Merger	Closing	Incentive	Award	[2019]

Form	of	IBERIABANK	Corporation	Restricted	Stock	Agreement

Director	Compensation	Policy,	as	adopted	April	27,	2021

Management	Cash	Incentive	Plan	Documents

Filed	
Here

Mngt	
Exh

Furn-
ished

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Incorporated	by	Reference	to

10.1(d)

Form Exh	No
10-K	
2020
10-Q
2Q09
10-Q
2Q09

10.2(d)

10.1(e)

Filing	Date

2/25/2021

8/6/2009

8/6/2009

10-Q
1Q16
10-Q
1Q19
10-Q
1Q20
10-Q
1Q21

10-Q
2Q17
10-K
2004
10-K
2006
10-Q	
1Q15
10-Q	
1Q16
10-Q	
1Q16
10-Q	
1Q17
10-Q	
1Q18
10-Q	
1Q19
10-Q	
1Q20
10-K	
2020

10-Q	
1Q19
10-Q	
1Q20
10-Q	
1Q21
10-Q	
1Q21
10-K	
2019
10-K	
2020
10-Q	
1Q21

10.6

5/6/2016

10.1

5/8/2019

10.1

5/8/2020

10.1

5/6/2021

10.1

8/8/2017

10.5(e)

3/14/2005

10.5(o)

2/28/2007

10.2

5/7/2015

10.2

5/6/2016

10.5

5/6/2016

10.2

5/8/2017

10.2

5/8/2018

10.2

5/8/2019

10.2

5/8/2020

10.3(l)

2/25/2021

10.3

5/8/2019

10.3

5/8/2020

10.2

5/6/2021

10.3

5/6/2021

10.4(e)

2/28/2020

10.4(f)

2/25/2021

10.4

5/6/2021

	 223

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

Exh	
No
10.5	
(a)
10.5	
(b)

10.6	
(a)

10.6	
(b)

10.6	
(c)
10.6	
(d)
10.6	
(e)
10.6	
(f)
10.6	
(g)
10.6	
(h)
10.6		
(i)
10.6		
(j)
10.6	
(k)
10.6		
(l)
10.6	
(m)
10.6	
(n)
10.6	
(o)
10.6	
(p)
10.6	
(q)
10.6	
(r)

10.7	
(a)

10.7	
(b)
10.7	
(c)
10.7	
(d)

Description	of	Exhibit	to	this	10-K	Report

Filed	
Here

Mngt	
Exh

Furn-
ished

Incorporated	by	Reference	to

Form Exh	No

Filing	Date

Executive	Bonus	Plan

X

8-K

10.1

10/27/2021

X

Management	Incentive	Plan	(as	amended	and	restated	April	26,	
2016)
Other	Exhibits	relating	to	Employment,	Retirement,	Severance,	or	Separation
February	2007	form	of	change-in-control	severance	agreement	
between	FHN	and	its	executive	officers
Form	of	Amendment	to	February	2007	form	of	change-in-
control	severance	agreement	between	FHN	and	its	executive	
officers
October	2007	form	of	change-in-control	severance	agreement	
between	FHN	and	its	executive	officers
Form	of	Change	in	Control	Severance	Agreement	offered	to	
executive	officers	from	November	2008	through	January	2021

X

X

X

X

Executive	Change	in	Control	Severance	Plan

Form	of	Pension	Restoration	Plan	(amended	and	restated	as	of	
January	1,	2008)

Form	of	Amendment	to	Pension	Restoration	Plan

Form	of	Amendment	No.	3	to	Pension	Restoration	Plan

Form	of	First	Horizon	Corporation	Savings	Restoration	Plan	

Letter	agreement,	dated	as	of	November	3,	2019,	by	and	
between	First	Horizon	and	D.	Bryan	Jordan
Form	of	Retention	Agreement	[entered	into	with	certain	
executives	of	First	Horizon,	November	2019]
Amended	and	Restated	Agreement,	dated	August	20,	2001,	
between	IBERIABANK	Corporation	and	Daryl	G.	Byrd	
Letter	agreement,	dated	as	of	November	3,	2019,	between	
IBERIABANK	Corporation	and	Daryl	G.	Byrd
Letter	agreement,	dated	as	of	November	3,	2019,	between	First	
Horizon	National	Corporation	and	Daryl	G.	Byrd
Form	of	letter	agreement	[entered	into	with	certain	executives	
of	IBERIABANK	Corporation,	November	2019]
Retention	Agreement	of	Anthony	J.	Restel,	dated	November	
3,2019
Conformed	copy	of	Separation	Agreement	and	General	Release	
[Michael	Brown]

Conformed	copy	of	offer	letter	[Hope	Dmuchowski]	

Documents	Related	to	Other	Deferral	Plans	and	Programs
Directors	and	Executives	Deferred	Compensation	Plan	[originally	
adopted	1985],	as	amended	and	restated	[2017],	with	forms	of	
deferral	agreement	and	2007	addendum	to	deferral	agreement
Form	of	Amendment	to	Directors	and	Executives	Deferred	
Compensation	Plan
Rate	Applicable	to	Participating	Directors	and	Officers	under	the	
Directors	and	Executives	Deferred	Compensation	Plan
Schedule	of	Deferral	Agreements	[Non-Employee	Directors,	
1995]

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Proxy	
2016

App	B

3/14/2016

8-K

10.7(a2)

2/26/2007

10-Q
3Q07
10-Q
3Q07

8-K

8-K

10-Q	
3Q07
10-K
2009
10-Q	
3Q11

8-K

8-K

8-K

10-K	
2020
10-K	
2020

10.7(a4)

11/7/2007

10.7(a5)

11/7/2007

10.2

11/24/2008

10.1

1/29/2021

10.7(e)

11/7/2007

10.7(d2)

2/26/2010

10.2

11/8/2011

10.1

7/17/2012

10.1

11/7/2019

10.2

11/7/2019

10.6(l)

2/25/2021

10.6(m)

2/25/2021

8-K

99.1

11/7/2019

10-K	
2020

8-K

8-K

8-K

10-Q	
2Q17

10-Q	
3Q07
10-Q	
3Q21
10-K
2018

10.6(o)

2/25/2021

10.1

7/2/2020

10.1

9/30/2021

10.1

11/9/2021

10.4

8/8/2017

10.1(a3)

11/7/2007

10.1

11/5/2021

10.7(d)

2/28/2019

	 224

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

Exh	
No

10.7	
(e)

10.7	
(f)

10.8	
(a)
10.8	
(b)
10.8	
(c)
10.8	
(d)
10.8	
(e)
10.8	
(f)
10.8	
(g)
10.8	
(h)

14

21

23

24

31(a)

31(b)

32(a)

32(b)

101

Description	of	Exhibit	to	this	10-K	Report
Form	of	First	Horizon	National	Corporation	Deferred	
Compensation	Plan	as	Amended	and	Restated	[formerly	known	
as	First	Tennessee	National	Corporation	Nonqualified	Deferred	
Compensation	Plan]
Form	of	Deferred	Compensation	Agreement	used	under	FHN’s	
Equity	Compensation	Plan	and	First	Tennessee	National	
Corporation	Non-Qualified	Deferred	Compensation	Plan,	along	
with	form	of	Salary,	Commission,	and	Annual	Bonus	Deferral	
Programs	Overview,	form	of	Deferred	Stock	Option	(“DSO”)	
Program	Summary,	and	description	of	share	receipt	deferral	
feature
Other	Exhibits	related	to	Management	or	Directors

Survivor	Benefits	Plan,	as	amended	and	restated	July	18,	2006

Other	Compensation	and	Benefit	Arrangements	for	Non-
employee	Directors

Description	of	Long-Term	Disability	Program

Form	of	Indemnity	Agreement	with	directors	and	executive	
officers	[2004	form]
Form	of	amendment	to	2004	form	of	Indemnity	Agreement	with	
directors	and	executive	officers
Form	of	Indemnity	Agreement	with	directors	and	executive	
officers	(April	2008	revision)

List	of	Certain	Benefits	Available	to	Certain	Executive	Officers

Description	of	2022	Salary	Rates	for	2021	Named	Executive	
Officers
Other	Exhibits

Code	of	Ethics	for	Senior	Financial	Officers

Subsidiaries	of	First	Horizon	Corporation

Accountant’s	Consents

Power	of	Attorney
Rule	13a-14(a)	Certifications	of	CEO	(pursuant	to	Section	302	of	
Sarbanes-Oxley	Act	of	2002)
Rule	13a-14(a)	Certifications	of	CFO	(pursuant	to	Section	302	of	
Sarbanes-Oxley	Act	of	2002)
18	USC	1350	Certifications	of	CEO	(pursuant	to	Section	906	of	
Sarbanes-Oxley	Act	of	2002)
18	USC	1350	Certifications	of	CFO	(pursuant	to	Section	906	of	
Sarbanes-Oxley	Act	of	2002)
XBRL	Exhibits
The	following	financial	information	from	First	Horizon	
Corporation’s	Annual	Report	on	Form	10-K	for	the	year	ended	
December	31,	2021,	formatted	in	Inline	XBRL:	
(i)	Consolidated	Balance	Sheets	at	December	31,	2021	and	2020	
(ii)	Consolidated	Statements	of	Income	for	the	Years	Ended	
December	31,	2021,	2020,	and	2019	
(iii)	Consolidated	Statements	of	Comprehensive	Income	for	the	
Years	EndedDecember	31,	2021,	2020,	and	2019.		
(iv)	Consolidated	Statements	of	Changes	in	Equity	for	the	Years	
Ended	December	31,	2021,	2020,	and	2019.
(v)	Consolidated	Statements	of	Cash	Flows	for	the	Years	Ended	
December	31,	2021,	2020,	and	2019.
(vi)	Notes	to	the	Consolidated	Financial	Statements

Filed	
Here

Mngt	
Exh

Furn-
ished

Incorporated	by	Reference	to

Form Exh	No

Filing	Date

10-Q	
3Q07

10.1(c)

11/7/2007

8-K

10(z)

1/3/2005

10-Q	
3Q06
10-K	
2020
10-Q	
2Q17
10-Q	
2Q17

8-K

8-K

10.8

11/8/2006

10.8(b)

2/25/2021

10.2

8/8/2017

10.3

8/8/2017

10.4

4/28/2008

10.5

4/28/2008

10-K
2008

14

2/26/2009

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

	 225

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

ITEM	15.	EXHIBITS	&	FINANCIAL	STATEMENT	SCHEDULES

Exh	
No

101.	
INS

101.	
SCH
101.	
CAL
101.	
DEF
101.	
LAB
101.	
PRE

104

Description	of	Exhibit	to	this	10-K	Report
XBRL	Instance	Document-the	instance	document	does	not	
appear	in	the	Interactive	Data	File	because	its	XBRL	tags	are	
embedded	within	the	Inline	XBRL	document

Inline	XBRL	Taxonomy	Extension	Schema

Inline	XBRL	Taxonomy	Extension	Calculation	Linkbase

Inline	XBRL	Taxonomy	Extension	Definition	Linkbase

Inline	XBRL	Taxonomy	Extension	Label	Linkbase

Inline	XBRL	Taxonomy	Extension	Presentation	Linkbase

Cover	Page	Interactive	Data	File,	formatted	in	Inline	XBRL	
(included	in	Exhibit	101)

Filed	
Here

Mngt	
Exh

Furn-
ished

Incorporated	by	Reference	to

Form Exh	No

Filing	Date

X

X

X

X

X

X

X

	 226

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

Item 16. Form 10-K Summary

ITEM	16.	FORM	10-K	SUMMARY

Not	applicable.

	 227

2021 FORM 10-K ANNUAL REPORT

    
Table	of	Contents

Signatures

SIGNATURES

Pursuant	to	the	requirements	of	Section	13	or	15(d)	of	the	Securities	Exchange	Act	of	1934,	the	registrant	has	duly	caused	this	
report	to	be	signed	on	its	behalf	by	the	undersigned,	thereunto	duly	authorized.

Date:	March	1,	2022

FIRST	HORIZON	CORPORATION																												

By:

/s/	Hope	Dmuchowski

Name:

	 Hope	Dmuchowski

Title:

Senior	Executive	Vice	President	and	Chief	
Financial	Officer
(Duly	Authorized	Officer	and	Principal	
Financial	Officer)

Pursuant	to	the	requirements	of	the	Securities	Exchange	Act	of	1934,	this	report	has	been	signed	below	by	the	following	
persons	on	behalf	of	the	registrant	and	in	the	capacities	and	on	the	dates	indicated.

Signature*

Title

Date*

Signature*

D.	Bryan	Jordan
D.	Bryan	Jordan

Jeff	L.	Fleming
Jeff	L.	Fleming

Kenneth	A.	Burdick
Kenneth	A.	Burdick

John	N.	Casbon
John	N.	Casbon

Wendy	P.	Davidson
Wendy	P.	Davidson

J.	Michael	Kemp,	Sr.
J.	Michael	Kemp,	Sr.

Vicki	R.	Palmer
Vicki	R.	Palmer

E.	Stewart	Shea	III
				E.	Stewart	Shea	III

Rajesh	Subramaniam
Rajesh	Subramaniam

R.	Eugene	Taylor
R.	Eugene	Taylor

President,	Chief	Executive	
Officer,	and	a	Director	
(principal	executive	officer)

Executive	Vice	President	
and	Chief	Accounting	
Officer	(principal	
accounting	officer)

Director

Director

Director

Director

Director

Director

Director

Director

Hope	Dmuchowski
Hope	Dmuchowski

Harry	V.	Barton,	Jr.
Harry	V.	Barton,	Jr.

Daryl	G.	Byrd
Daryl	G.	Byrd

John	C.	Compton
John	C.	Compton

William	H.	Fenstermaker
William	H.	Fenstermaker

Rick	E.	Maples
Rick	E.	Maples

Colin	V.	Reed
Colin	V.	Reed

Cecelia	D.	Stewart
Cecelia	D.	Stewart

Rosa	Sugrañes
Rosa	Sugrañes

*

*

*

*

*

*

*

*

*

*

*By:	/s/	Clyde	A.	Billings,	Jr.
	Clyde	A.	Billings,	Jr.
	As	Attorney-in-Fact

March	1,	2022

Title
Senior	Executive	Vice	
President	and	Chief	
Financial	Officer	(principal	
financial	officer)

Director

Director

Director

Director

Director

Director

Director

Director

Date*

*

*

*

*

*

*

*

*

*

	 228

2021 FORM 10-K ANNUAL REPORT